News & Analysis as of

Medicare Change of Ownership Centers for Medicare & Medicaid Services (CMS)

Arnall Golden Gregory LLP

CMS Announces Changes for SNFs on Care Compare Website

The Centers for Medicare & Medicaid Services (“CMS”), Center for Clinical Standards and Quality recently announced upcoming changes to skilled nursing facility (“SNF”) profiles on the Medicare Care Compare website. Care...more

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

Proposed Legislation Focuses on Private Equity and REITs in Healthcare

Efforts to draw attention to and, in some instances, dissuade private equity investment in healthcare have been on the rise. For example, in late 2023, the Centers for Medicare & Medicaid Services finalized a rule increasing...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

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

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Hospice 36-Month Rule

The Centers for Medicare & Medicaid Services (“CMS”) has finalized 2024 home health rules to include application of the home health “36-month rule” to hospice providers. The revised rule will forbid any change in majority...more

Arnall Golden Gregory LLP

CMS Announces Enhanced Oversight for New Hospices in Four States

Effective July 13, 2023, the Centers for Medicare & Medicaid Services (“CMS”) announced a period of enhanced oversight for new hospices in Arizona, California, Nevada, and Texas. According to the Medicare Learning Network...more

Venable LLP

A Proposed New Regulatory Environment for Medicare Hospice Providers: Application of the 36-Month Rule, Increasing Enrollment...

Venable LLP on

On July 10, 2023, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (Proposed Rule) that would (i) include hospices in the 36-month rule ownership transfer restrictions that currently exist for home...more

Polsinelli

“36-Month Rule” Anticipated to Expand to Hospice

Polsinelli on

On July 10, the Centers for Medicare & Medicaid Services (“CMS”) issued a Proposed Rule that would extend the “36-Month Rule” to Hospice providers. The 36-Month Rule refers to 42 C.F.R. § 424.550(b), which currently...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

Husch Blackwell LLP

Significant Change in Medicare Enrollment Risk Categories for SNFs

Husch Blackwell LLP on

The Affordable Care Act mandated that the Centers for Medicare and Medicaid Services (“CMS”) establish risk categories for Medicare enrollment, which are used by CMS to determine what level of scrutiny to give provider...more

King & Spalding

Accreditation Organizations are Required to Notify CMS of Change of Ownership Under Final Rule

King & Spalding on

On April 29, 2022, CMS published a final rule requiring Accreditation Organizations (AOs) to notify CMS of changes of ownership (CHOWs). Effective June 28, 2022, an AO will need to notify CMS when undergoing or negotiating a...more

King & Spalding

CMS Looks to Strengthen Oversight of Medicare Accrediting Organizations

King & Spalding on

On May 2, 2019, CMS issued a proposed rule that would add requirements and a specific process to address changes of ownership as they relate to the sale, transfer, and/or purchase of assets of CMS-approved Accrediting...more

McDermott Will & Emery

CMS Policy Memorandum Clarifies Disincentives to Buyer’s Rejection of Seller’s Medicare Agreement

McDermott Will & Emery on

In a September 6, 2013, policy memorandum, effective immediately, the Centers for Medicare & Medicaid Services (CMS) detailed its policy ensuring that providers that choose to reject assignment of the seller’s Medicare...more

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