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Disclosure Requirements Health Care Providers Centers for Medicare & Medicaid Services (CMS)

Stevens & Lee

CMS Issues Updated Hospital Price Transparency Guidance and Related RFI

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The Centers for Medicare & Medicaid Services (CMS) released new Updated Hospital Price Transparency Guidance (Guidance) to “strengthen the Hospital Price Transparency requirements, requiring hospitals to post the actual...more

Robinson+Cole Health Law Diagnosis

CMS Issues Guidance and Requests Information to Promote Hospital Price Transparency Compliance and Enforcement Efforts

On May 22, 2025, the Centers for Medicare & Medicaid Services (CMS) took a series of actions to promote enhanced price transparency compliance by hospitals and identify challenges thereto, in order to inform future price...more

McDermott Will & Emery

CMS Updates SNF Attachment Guidance Ahead of May 1 Enrollment Deadline

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Skilled nursing facilities (SNFs) historically have been required to disclose ownership and managerial control information as part of their Medicare enrollment. However, these requirements were significantly expanded to...more

Bond Schoeneck & King PLLC

Consider Support from Bond to Navigate the Complex Process

Bond’s health care and long term care practice groups want to ensure you’re ahead of the curve on a compliance requirement that will affect the nation’s skilled nursing facilities and, potentially, the organizations they work...more

McDermott+

Breaking Down the New No Surprises Act FAQs Post-TMA III

McDermott+ on

On January 14, 2025, the US Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments), along with the Office of Personnel Management (OPM), jointly issued Part 69 of a series of...more

McGuireWoods LLP

CMS Nearly Doubles Prior Stark Self-Disclosure Dollar Record in 2024

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The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2024 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark...more

Wiley Rein LLP

Trump Prioritizes Health Care Pricing Transparency in New Executive Order

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On Tuesday, February 25, 2025, President Trump issued an Executive Order (EO), “Making America Healthy Again By Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information.” The EO aims to improve...more

Gardner Law

Sunshine Act Compliance: How to Take Action to Meet Reporting Requirements and Avoid Costly Penalties

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The clock is ticking for medical device and pharmaceutical companies to fulfill their obligations under the Physician Payments Sunshine Act (the "Sunshine Act"). With the reporting deadline of March 31 looming and CMS...more

Sheppard Mullin Richter & Hampton LLP

Deadline Quickly Approaching for NY Nursing Homes and Owners/Operators Regarding CMS Star-Rating Postings

Effective as of December 26, 2024, each nursing home facility (“Facility”) in New York State will be required to post its overall Centers for Medicare & Medicaid Services (“CMS”) rating, as well as its ratings for (i) health...more

Baker Donelson

Updates to SNF Off-Cycle Revalidation Guidance Continue

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As skilled nursing facilities (SNFs) seek to understand and meet the new expansive Medicare enrollment reporting obligations, the Centers for Medicare and Medicaid Services (CMS) issued several updates to its Guidance for SNF...more

Dentons

Ep. 40 – Complying with Expanded Medicare Disclosure Requirements for Skilled Nursing Facilities

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The Centers for Medicare & Medicaid Services (CMS) is in the midst of an off-cycle revalidation process for all Medicare-participating skilled nursing facilities (SNFs), requiring them to submit much more information...more

Polsinelli

Calling All SNFs… and All of Your Operational Associates – Get Ready Now: Sweeping New Disclosure Requirements Under The Updated...

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Skilled Nursing Facilities and their operational associates need to prepare themselves now for new disclosure requirements that require much greater disclosure of ownership as well as disclosure from a much broader class of...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

K&L Gates LLP

The Wait Is Over: Revised CMS Enrollment Form Puts SNF Ownership and Management Under a Microscope

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With the release of an updated CMS-855A enrollment form (855A), skilled nursing facilities (SNFs) will be required to identify substantially more detailed ownership and control information to Centers for Medicare and Medicaid...more

Fox Rothschild LLP

CMS to Require All Skilled Nursing Facilities to Complete Off-Cycle Revalidation

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The Centers for Medicare & Medicaid Services (CMS) recently announced it will require off-cycle revalidation of skilled nursing facilities (SNFs) through the end of 2024. During this process, CMS will collect ownership,...more

Morgan Lewis - ML Benefits

CMS Disclosures Due October 15: Is Your Plan’s Rx Coverage Still Creditable?

The Inflation Reduction Act (IRA) made several changes to Medicare Part D that may impact whether employer-sponsored coverage will be creditable for the 2025 plan year. With open enrollment season about to begin, plan...more

Bass, Berry & Sims PLC

CMS Proposes New Mandatory Value-Based Payment Initiative: The Transforming Episode Accountability Model

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The Centers for Medicare & Medicaid Services (CMS) recently proposed the Transforming Episode Accountability Model (TEAM) – a new, mandatory, episode-based alternative payment model in the Fiscal Year 2025 Hospital Inpatient...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

McDermott Will & Emery

Private Equity and REITs, Take Note! CMS Finalizes Nursing Facility Ownership Disclosure Requirements

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On November 17, 2023, the US Department of Health and Human Services (HHS) published a final rule requiring nursing facilities participating in Medicaid and skilled nursing facilities participating in Medicare to disclose...more

Venable LLP

Looming CTA Disclosure Requirements and Healthcare Providers

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The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...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

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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

Polsinelli

Ownership Transparency Continues for Skilled Nursing Facilities with Additional Required Disclosures

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On November 15, 2023, CMS finalized a proposed rule that will require Skilled Nursing Facilities (“SNFs”) to disclose the identity of an expanded array of ownership and control interests in SNFs beyond the information that is...more

Polsinelli

What the Health Care Industry Needs to Know About the Corporate Transparency Act

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A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more

ArentFox Schiff

No More Surprise Medical Bills: Providers Score Yet Another Victory as Texas Court Again Vacates Provisions of Biden...

ArentFox Schiff on

On August 24, 2023, health care providers in Texas scored yet another victory when a federal court vacated additional portions of the Biden Administration’s rulemaking under the federal No Surprises Act (the Act). This marked...more

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