Additional Disclosable Parties (ADPs)

CMS recently implemented new requirements aimed at increasing transparency and accountability in the nursing home industry. Effective as of October 1, 2024, these changes require nursing homes to disclose extensive ownership and management details through the revised Form CMS-855A. This update addresses longstanding concerns about financial exploitation in the industry, particularly through related-party transactions that allow owners to funnel funds intended for resident care into their own affiliated entities.

The revised Form CMS-855A now includes a SNF Attachment, which replaces previous sections and demands detailed disclosures about ownership structures, managerial control, and relationships with Additional Disclosable Parties (ADPs). ADPs include any entities providing services such as property leases, administrative management, clinical consulting, or financial oversight. Nursing homes must also submit organizational charts that map out ownership and relationships with related-parties.

A key part of this initiative is the proactive revalidation process, set to occur between October and December 2024, during which Medicare contractors will collect this information from facilities. Nursing homes in Florida, Georgia, and South Carolina, have been granted an extension until May 1, 2025, due to emergency efforts. These updated requirements build on existing mandates under Section 1124(a) of the Social Security Act by incorporating provisions from Section 1124(c), which broadens the scope of ADPs. These expanded disclosures will make it easier to identify financial mismanagement and related-party exploitation without the need for an exhaustive discovery process.