News & Analysis as of

Change of Ownership Disclosure Requirements

Bricker Graydon LLP

The Mandatory SNF Provider Enrollment Revalidation Deadline is May 1, 2025

Bricker Graydon LLP on

The Centers for Medicare and Medicaid Services (CMS) has long required skilled nursing facilities (SNFs) enrolled in the Medicare and Medicaid programs to disclose information regarding organizational structure, governing...more

Holland & Knight LLP

Significant Changes to SNF Disclosure Requirements Prompt Need for Regulatory Review

Holland & Knight LLP on

To enhance quality of operations and increase transparency in ownership within skilled nursing facilities (SNFs), the Centers for Medicare & Medicaid Services (CMS) issued its Final Rule for ownership disclosures for Medicare...more

Arnall Golden Gregory LLP

CMS Releases Update to CMS-855A Enrollment Form With Significant Increase in Disclosure Requirements for SNFs

The Centers for Medicare & Medicaid Services (“CMS”) has issued an updated version of the Form CMS-855A that requires additional disclosures for skilled nursing facilities (“SNFs”). Effective October 1, 2024, the revised Form...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

McCarter & English, LLP

Next Stop, Revalidation Station: CMS Final Rule for Nursing Home Transparency to Prompt Off-Cycle Revalidation, Revised Form...

Nursing facilities should prepare to provide the Centers for Medicare & Medicaid Services (CMS) with additional information about their ownership, their managing employees and the parties providing certain financial and...more

Goodwin

Additional Disclosure Required: CMS Implements Substantial Changes to Reporting Skilled Nursing Facility Ownership Information

Goodwin on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that will require skilled nursing facilities (SNFs) to disclose an expanded array of ownership, managerial, and control information...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues Proposed Rule Requiring Nursing Homes to Disclose Additional Ownership Information, Including Ties to Private Equity...

On February 15, 2023, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would require nursing homes enrolled in Medicare and Medicaid to disclose new information about their ownership and...more

Goulston & Storrs PC

Evolving Private Company M&A Considerations in the COVID-19 Era

Goulston & Storrs PC on

The virus that causes COVID-19 has ushered in unprecedented times for our country and our global community. Certainly, the pandemic is impacting the way M&A transactions are looked at, papered, implemented, and even priced....more

Burr & Forman

TTB Adopts Grace Period for Beer, Wine and Spirits Wholesalers and Importers to Disclose Change in Ownership

Burr & Forman on

On July 5, 2019, the Alcohol and Tobacco Tax and Trade Bureau (“TTB”) issued TTB Industry Circular 2019-2 advising that certain eligible beer, wine, and spirits wholesalers and importers shall have until December 31, 2019 to...more

Pillsbury Winthrop Shaw Pittman LLP

Proposals Should Carefully Address Pending Corporate Deals

Lockheed Martin’s recent success in overcoming GAO protests shows that fully explaining a transaction in the works can be a key proposal element. The GAO has denied three protests of a high-profile contract award to...more

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