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Push for Greater Nursing Home Ownership Transparency Continues With Introduction of the Linking Investors and Nursing Home Quality...

The nursing home industry has seen increased efforts by the federal government to enhance transparency, with a focus on ownership disclosures (both past and present ownership) of facilities enrolled in Medicare. The efforts...more

Considerations for Incoming Operators of Senior Living Facilities to Mitigate Risks With Distressed Former Operators: A Case...

An incoming operator of a senior living facility should consider and mitigate risks of potential successor liability when agreeing to operate a new facility.1 This is particularly true when the former operator has filed for...more

Returned Provider Relief Funds for Failure to Report? You May Be Able to Get them Back

The Health Resources & Services Administration (“HRSA”) has allowed Provider Relief Fund (“Fund”) recipients who failed to timely report on use of Funds, but still retained them, to request to report late. We previously...more

HHS Extends ARP Spending Deadline to March 31, 2025 for HCBS Medicaid Recipients

States now have through March 31, 2025 to use the federal medical assistance percentage (FMAP) funding made available by the American Rescue Plan Act (ARPA). The announcement was made by the U.S. Department of Health and...more

HRSA Offers Second Chances in Provider Relief Funding and Reporting

The initial phase of Provider Relief Funds (“Funds”) was distributed in April 2020, and since then, many providers have been playing catch up. The Health Resources & Services Administration (HRSA) recently addressed two...more

Georgia COVID-19 Prevention and Mitigation Assisted Living Communities and Personal Care Homes Grant To Provide $47 Million for...

Georgia assisted living communities and personal care homes will be eligible for up to $100,000 of grant funding to reimburse COVID-related expenses. Georgia Governor Brian P. Kemp announced he will award over $217 million...more

CMS Releases Skilled Nursing CHOW (and Ownership) Data

For the first time, the Centers for Medicare & Medicaid Services (CMS) has released data publicly on skilled nursing facility changes of ownership (CHOWs)). The data, which was released on April 20, 2022, includes information...more

HRSA Reopening Provider Relief Fund Reporting Period 1 Portal for “Extenuating Circumstances”

On April 11, 2022, the Health Resources & Services Administration (“HRSA”) opened a portal that allows providers who were required to report on use of funds under Provider Relief Fund Reporting Period 1, but failed to do so,...more

Biden’s 2023 Proposed Budget Aims to Hold Long-Term Care Facility Owners Accountable

President Biden recently announced his Federal Fiscal Year Budget Proposal, which included a proposal to hold long-term care (LTC) facility owners accountable for noncompliant closures and substandard care. Specifically,...more

Proposal Calls for Increased Transparency of Ownership for Privately Owned Nursing Homes

Continuing the theme of increased transparency of ownership of nursing homes included in the 2010 Affordable Care Act, the White House issued a Fact Sheet titled “Protecting Seniors and People with Disabilities by Improving...more

Illinois Bill Pushes Long-Term Care Operators to Reveal Ownership Interests

Illinois legislators are taking action to increase scrutiny of nursing home ownership. The disclosure provisions are included in the Compromise Nursing Home Rate Reform Bills (HB 4678)....more

Georgia Licensing Now Requiring Affidavit of Financial Stability in Support of Initial and Change of Ownership Applications

In response to media reports regarding alleged deficient practices in some of Georgia’s long-term care facilities, House Bill 987 (“HB 987”) was signed into law on June 30, 2020, amending Title 31 of the O.C.G.A....more

HRSA Updates (and Pushes Back) Release of Phase 4 Relief Funds

The Health Resources and Services Administration (HRSA) recently posted an updated timeframe for disbursement of Phase 4 Provider Relief Funding (Funding). HRSA previously expected to begin disbursing Funding in mid-December...more

Changes of Ownership and Provider Relief Funds: HRSA Issues Guidance on Phase 4 Funding and Reporting of CHOWs

In a previous article, we discussed the Health Resources & Services Administration’s (HRSA) Phase 4 Provider Relief Funding (“Funding”). In the Funding announcement, HRSA and the Department of Health & Human Services (HHS)...more

California Passes Major Hospice Reform, Including Minimum One Year New License Moratorium

California Governor Gavin Newsom signed into law two pieces of legislation intended to improve hospice oversight in the state on October 4, 2021. The laws resulted in part from the U.S. Department of Health and Human...more

HHS Announces New Phase 4 Provider Relief Funding

Healthcare providers and related advocacy groups have been working for months to secure Phase 4 Provider Relief Funding (“Funds”). On September 10, 2021, the Department of Health & Human Services announced that it would make...more

Provider Relief Funds: CHOW Developments and Other Updates

As Provider Relief Fund (PRF) recipients look towards the end of the first PRF reporting period on September 30, 2021, the Department of Health & Human Services (HHS) and Health Resources & Services Administration (HRSA) have...more

The Georgia Department of Community Health Approves New Requirements for Personal Care Homes and Assisted Living Communities

On August 12, 2021, the Georgia Department of Community Health unanimously approved revisions to the rules for Personal Care Homes (PCHs) and Assisted Living Communities (ALCs). These revisions modify the Regulations for...more

Provider Relief Funds: New FAQs Shine a Light on Appeals and Reporting Deadlines

With both providers and the Department of Health & Human Services (HHS) focused on the Provider Relief Fund (PRF) reporting requirements since the beginning of 2021, relatively few Frequently Asked Questions (FAQs) issued by...more

CHOW Considerations for Medicare Chain Providers: The Importance of Knowing Your MAC

All Medicare providers must update their enrollment information to reflect changes in ownership (CHOWs) within 30 days after the CHOW. Providers must report CHOWs to the applicable Medicare Administrative Contractor (MAC)....more

No Need for Certificate of Need: Florida Eliminates Certificate of Need Review for Specialty Hospitals

Florida follows in the footsteps of states such as New Hampshire and Wisconsin by paring back its Certificate of Need (CON) program for specialty hospitals, effective July 1, 2021. Florida first introduced its CON program in...more

Georgia DCH Publishes Proposed Rules that Update Operational Requirements for Personal Care Homes and Assisted Living Communities

On June 10, 2021, the Georgia Department of Community Health provided public notice of its intent to revise the regulations for Personal Care Homes and Assisted Living Communities. The revised regulations are intended to...more

Georgia Department of Public Health Issues Additional Update on Reopening Guidance for Long-Term Care Facilities

On May 17, 2021, the Georgia Department of Public Health (DPH) issued an updated Administrative Order regarding reopening guidance for long-term care facilities. Commissioner Toomey previously issued an Order of reopening...more

New Jersey Legislation Would Increase Scrutiny on Nursing Home CHOWs and Bridging Arrangements

In response to the number of COVID-19 related deaths in New Jersey long-term care facilities, the State engaged a consulting firm to conduct a review and recommend changes.  The consultant’s report noted that, “[n]ationally...more

A New Phase of Provider Relief Funds May Be on the Horizon

The Department of Health & Human Services (HHS) is expected to announce a new phase of Provider Relief Funding (PRF) that would likely cover COVID-related expenses and losses during the third and fourth quarters of 2020 (and...more

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