Publications by Sean J. Fahey

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Nursing Home Update: New CMS Surveyor Guidance Calls for Admission Agreement Reviews

[03/27/25]

Revisiting Disclosure Requirements for Skilled Nursing Facilities as Deadline Approaches

[03/20/25]

Nursing Home Update: CMS Extends Implementation Date of Surveyor Guidance Changes in Appendix PP

[03/10/25]

Post-Acute Compliance Program Update: OIG Recommendations on Medical Director Agreements and Roles

[03/04/25]

Nursing Home Update: CMS Updates and Expands Surveyor Guidance for Transfers and Discharges

[02/25/25]

Hospice Update: CMS Pauses Implementation of the Hospice Special Focus Program for Calendar Year 2025  

[02/17/25]

Post-Acute Enrollment Update: CMS Expands Enhanced Oversight to Include Reactivating Providers

[02/14/25]

Nursing Home Update: CMS Updates and Expands Surveyor Guidance for Medical Director Role and Mental Health Assessments

[02/04/25]

Hospice Update: Surveyors Called to Identify Quality of Care Concerns and Potential Fraud Referrals

[01/29/25]

Rhode Island Law Update: New Law Allows Cameras in Nursing Homes and Assisted Living Facilities

[01/23/25]

Post-Acute and Enrollment Update: CMS Issues Section 1135 Waivers for California Wildfires

[01/17/25]

Illinois Long-Term Care Law Update: Changes to Nursing Home Change of Ownership Process

[01/15/25]

Nursing Home Update: CMS Confirms Acute Respiratory Illness Reporting Requirements

[01/08/25]

CMS Revises Core Appendix Q Guidance on Immediate Jeopardy

[12/30/24]

Nursing Home 2024 Legal and Regulatory Year in Review

[12/23/24]

CMS Updates Disclosure Requirements for Skilled Nursing Facilities – Provider Enrollment Off-Cycle Revalidations

[12/17/24]

Post-Acute Compliance Program Update: OIG Proposes Amendments to Exclusion Rules

[12/11/24]

Post-Acute Provider Update: CMS Clarifies Unannounced Site Verification Visits

[12/03/24]

OIG Issues Highly Anticipated Industry Segment-Specific Compliance Program Guidance for Nursing Facilities

[11/25/24]

OIG Reveals Nursing Homes Challenged with Life Safety and Emergency Preparedness Regulations

[11/21/24]

Home Health Update: CMS Finalizes New Acceptance-to-Service Policy Requirement

[11/14/24]

CMS Final Rule Calls for Ongoing Respiratory Illness Reporting through NHSN for Nursing Homes

[11/06/24]

CMS Extends Deadline for Disclosure Requirements for Skilled Nursing Facilities – Provider Enrollment Off-Cycle Revalidations

[11/06/24]

Nursing Home Update: Upholding Resident Voting Rights

[10/28/24]

New Medicare Disclosure Requirements for Skilled Nursing Facilities – Provider Enrollment Off-Cycle Revalidations – Watch for a Revalidation Request

[10/22/24]

Buyer Beware: CMS Finalizes Ownership Disclosure Requirements for Medicare Skilled Nursing Facilities and Medicaid Nursing Facilities

[12/20/23]

Connecticut Long-Term Care Law Update: Changes to Nursing Home Change of Ownership Process

[10/20/23]

Nursing Home Update: CMS Recasts the Civil Money Penalty Reinvestment Program 

[10/10/23]

Nursing Home Update: OIG Reveals Failure to Comply with Nursing Home Life Safety and Emergency Preparedness Regulations

[09/28/23]

Nursing Home Arbitration Agreements: Recent Trends in Citation Risks and Solutions

[09/22/23]

CMS Proposes Minimum Staffing Standards for Long-Term Care Facilities

[09/06/23]

Nursing Home Update: Addressing Sexual Interactions Between Cognitively Impaired Residents – Policy Reviews Needed

[08/21/23]

Skilled Nursing Update: CMS Finalizes Changes to SNF Value-Based Purchasing, SNF Quality Reporting Program and Civil Monetary Penalties

[08/11/23]

Arizona Assisted Living Law Update: New Assisted Living Disclosures to Emergency Responders and Hospital Discharge Requirements

[08/03/23]

Nursing Home Update: CMS Begins Posting Nursing Home Ownership and Nursing Home Performance Data

[07/27/23]

CMS Hammers Down on New Hospices and Hospice Changes of Ownership in Four States 

[07/18/23]

Hospice Update: CMS Proposes Informal Dispute Resolution Program, Starting Special Focus Program and Change of Ownership Restrictions 

[07/12/23]

Post-Acute Update: CMS Gives Nursing Homes and Home Health Agencies an Admission Playbook

[07/05/23]

Indiana Assisted Living Law Update: New Requirements for Memory Care Providers  

[06/27/23]

Skilled Nursing Facility Update: CMS Begins National Probe and Educate Audits

[06/23/23]

“Lawyers weigh in on their healthcare clients’ biggest concerns,” Modern Healthcare, June 2023

[06/19/2023]

Iowa Long-Term Care Law Update: Changes to Nursing Home Change of Ownership Process

[06/12/23]

CMS Final Rule Terminates COVID Vaccination Mandate and Finalizes Regulations for Long-Term Care Facilities

[06/05/23]

Skilled Nursing Update: CMS Proposes Changes to SNF Value-Based Purchasing, SNF Quality Reporting Program and Civil Monetary Penalties

[05/30/23]

Long-Term Care Update: Indiana Sets Requirements for Temporary Health Care Staffing Agencies

[05/23/23]

Skilled Nursing Update: CMS Recasts Skilled Nursing Visitation Action Items or Post-PHE Visits 

[05/11/23]

Nursing Home Update: CMS Unwinds Vaccine Mandate and More Regulations as Public Health Emergency End Nears

[05/02/23]

Assisted Living Facility Update: CMS Finds Residency Agreements Fail to Meet HCBS Requirements

[03/30/23]

Key Areas of Focus for Skilled Nursing Facilities as the Public Health Emergency Ends

[03/28/23]

Proposed Ownership Disclosure Requirements for Medicare Skilled Nursing Facilities and Medicaid Nursing Facilities

[02/21/23]

Skilled Nursing Transactions Update: CMS Enhances Scrutiny of Changes of Ownership for Skilled Nursing Facilities

[11/18/22]

Skilled Nursing Update: CMS Strengthens Oversight of the Special Focus Facility Program

[11/07/22]

Skilled Nursing Compliance Update: CMS Hands Surveyors Revised Details on How to Review the Staff Vaccine Requirement

[10/31/22]

Skilled Nursing Update: CMS Adds Extra Time to Review 2019 Proposed Regulations That Impacted Key Skilled Nursing Regulations

[07/18/22]

Nursing Home Update: CMS Updates and Expands Surveyor Guidance for Nursing Homes for Phase 2 and 3 Requirements of Participation – Key Areas and Timeline

[06/30/22]

"Complete Healthcare Compliance Manual," Healthcare Compliance Association, 2022. (Available for Purchase)

Skilled Nursing Update: White House Creates Its Vision Board for Nursing Homes with Staffing Requirements, Ownership Transparency and Higher Fines

[03/08/22]

Skilled Nursing Update: CMS Enhances Skilled Nursing Visitation Guidance – Visitor Testing, Air Quality Improvements and CMP Funds Available

[02/04/22]

Skilled Nursing Update: CMS Hands Surveyors Details on How to Review the Staff Vaccine Requirement

[01/31/22]

Skilled Nursing Compliance Program Update: Five-Star Quality Rating Changes and Staffing

[01/18/22]

CMS Updates Skilled Nursing Visitation Guidance and Enhanced Recommended Visitation Protocols

[01/11/22]

Skilled Nursing Update: CMS Adds New F Tag and Survey Guidance on COVID-19 Vaccine Requirement Regulations – REVISED

[01/06/22]

CMS FAQs Detail Best Practices and Key Elements for Skilled Nursing Visitation

[12/27/21]

Skilled Nursing Visitation Update: Key Elements of CMS’s Sweeping Visitation Reset

[11/22/21]

Skilled Nursing Surveys: CMS Hammers Down on Quality of Life and Quality of Care

[11/15/21]

Indiana’s New Advance Directives Law

[07/01/21]

PDPM Adjustments, Vaccine Reporting and New Rates Highlight CMS FY 2022 SNF PPS Proposed Rule

[05/27/21]

Skilled Nursing Facility Compliance Update – OIG Rolls Out New Focus Areas

[05/19/21]

Nursing Homes: CMS Interim Final Regulations – New Mandates on Vaccine Offering, Education and Reporting

[05/11/21]

CMS Terminates Several Skilled Nursing Facility Regulatory Blanket Waivers

[04/27/21]

National Healthcare Decisions Day – Key Elements of Residents’ Advance Directives for Nursing Homes

[04/13/21]

New OSHA Enforcement Efforts Target Health Care Employers

[03/30/21]

CMS Recasts Infection Control Focused Survey Triggers for Nursing Homes

[01/26/21]

Eight Key Elements of the Hospice Medicare Survey and Certification Process Created in New Law

[01/19/21]

The Future of Post-Acute Administrative Enforcement and Appeals – White House Proposes Ten “Principles of Fairness”

[10/19/20]

Post-Acute Emergency Preparedness: Do You Qualify for a Testing and Training Exemption?

[10/06/20]

HHS Updates Details on Nursing Home Infection Control Distribution Qualification and Uses – Four Keys

[09/24/20]

Seven Keys to the HHS $2 Billion Provider Relief Fund Nursing Home Performance-Based Incentive Distribution

[09/04/20]

COVID-19 CARES Funding Relief to Assisted Living Facilities – Five Keys and Five Actions to Take Now

[09/03/20]

CMS Expands Skilled Nursing and CLIA Survey Activity and Guidance

[08/31/20]

Nursing Homes: CMS Interim Final Regs – Increased Fines and Requirement to Test Nursing Home Residents and Staff for COVID-19

[08/26/20]

Skilled Nursing COVID-19 Antigen Testing: CLIA Certificates of Waiver and New Policies Needed

[07/17/20]

"Adapting Skilled Nursing Compliance and Ethics Programs to a COVID-19 World," Journal of Health Care Compliance, July 2020.

Creating Swing Beds: Key Regulatory, Operational, Billing and Compliance Considerations Under the CMS Blanket Waivers

[07/08/20]

Home Health PPS Proposed Rule CY2021: Some Good News

[06/29/20]

Skilled Nursing Reopening to Visitors: Key Questions for Revising Your Visitor Policies and Procedures from CMS

[06/25/20]

Reimagining Skilled Nursing Infection Control: Five Key Areas of Focus from the CDC

[06/18/20]

Reimagining Skilled Nursing Compliance Programs: Five Key Areas of Focus from the DOJ

[06/09/20]

HHS Releases COVID-19 CARES Funding Relief FAQs for Skilled Nursing Facilities – Details on Distribution Calculations and Use of Funds

[06/03/20]

Infection Control and Auditing CARES Act Provider Relief Funds – OIG Unveils COVID‑19 Skilled Nursing Focus 

[05/27/20]

HHS Distributing $4.9B in COVID-19 CARES Funding Relief to Skilled Nursing Facilities – Five Actions to Take Now

[05/22/20]

Policy Updates to Compliance Program Needed When Creating “COVID-19 Ready” Skilled Nursing Facilities and Units

[05/18/20]

Fine, Everything Is Being Fined! Two New F-Tags and Three Key Developments For Nursing Homes Reporting COVID-19 Cases to CDC

[05/07/20]

Some Is Good, But More (Reporting) Is Better – 9 Key Points on the New Skilled Nursing CDC COVID-19 Reporting Regulations

[05/01/20]

Ten Takeaways from the CMS “Ask Me (Almost) Anything” Q&A on Skilled Nursing Facilities and Nursing Facilities Issues

[04/27/20]

CMS to Require Nursing Homes to Report COVID-19 Cases to CDC, Residents and Resident Representatives

[04/20/20]

Post-Acute and Long-Term Care Issues in Health Care Mergers & Acquisitions: Three Short-Term Fixes to Avoid Long-Term Issues

[04/16/20]

National Healthcare Decisions Day – Know Your Residents’ Advance Directives!

[04/16/20]

CMS Memo Offers COVID-19 Discharge, Transfer and Cohorting Guidance for Skilled Nursing Facilities and Nursing Facilities

[04/14/20]

Updates on SNF Blanket Waivers – Physician Delegations

[04/10/20]

Creating COVID-Only Skilled Nursing Facilities: Advantages and Disadvantages

[04/09/20]

Medicare’s Interim Final Rule Addressing COVID-19 Provides Some Home Health and Hospice Relief

[04/01/20]

"Board of Directors Oversight of Skilled Nursing Facility Compliance Programs," Compliance Today, April 2019.

Skilled Nursing Facilities: Compliance Lessons from Kirkland, Washington

[03/31/20]

CARES Act Cares for Home Health and Hospice

[03/27/20]

Guidance for Use of Certain Industrial Respirators by Health Care Personnel

[03/25/20]

CMS Prioritizes Certain Provider Surveys and Halts Others in Response to COVID-19

[03/25/20]

Do SNFs, HHAs and Hospice Providers Need Individual Section 1135 Waivers for COVID-19 Activities?

[03/20/20]

COVID-19 Guidance for Home Health Agencies

[03/18/20]

CMS Offers COVID-19 Guidance and Flexibility to PACE Programs

[03/18/20]

CMS Memo Offers Additional Revised COVID-19 Guidance for Skilled Nursing Facilities

[03/16/20]

CMS Suspends Most Non-Emergency Inspections Across the United States with Goal to Focus on Infectious Diseases and Abuse

[03/06/20]

Emergency! OIG SNF Audits Reveal Failure to Comply with Life Safety and Emergency Preparedness Regulations

[02/13/20]

CMS Announces Post-Acute Priorities for 2020 – Final Regulations, State Operation Manual Updates, Home Health and Hospice Survey Process Revisions

[12/20/19]

CMS Memo Addresses Status of Interpretive Guidance for Phase 3 Skilled Nursing Facility Regulations and Arbitration Agreements

[11/25/19]

Skilled Nursing Licensure Update: Changes to Kansas Skilled Nursing Change of Ownership Law

[11/06/19]

California Law Update: Changes to Firearm Laws for Assisted Living Facilities

[10/31/19]

Red Alert: CMS Nursing Home Compare Website to Add Red Alert Icons for Facilities with Abuse and Neglect Citations

[10/11/19]

Next Up for Patient Driven Payment Model? Key Legal and Compliance Considerations Ahead for PDPM

[10/08/19]

Countdown to Phase 3 – Skilled Nursing Infection Preventionist

[10/02/19]

Ohio Law Update: Changes to Skilled Nursing Change of Operator Process

[09/24/19]

"Skilled Nursing Required Compliance and Ethics Program - Changes and Key Components" Journal of Health Care Compliance, September-October 2019.

Skilled Nursing Arbitration Agreements Are Back with Restrictions – CMS Issues Final Regulations on Skilled Nursing Arbitration Agreements

[08/14/19]

CMS Proposes One-Year Delay for Certain Phase 3 Skilled Nursing Requirements – Changes Made to Compliance and Ethics Programs and Quality Assurance and Performance Improvement Programs

[07/17/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #8 – Respond and Take Corrective Action

[07/15/19]

New Admission Disclosure Requirements for Indiana Skilled Nursing and Assisted Living Facilities

[06/28/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #7 – Consistent Enforcement of Discipline Procedures

[06/28/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #6 – Auditing and Monitoring Procedures to Promote Compliance

[06/21/19]

Staff Training and Policy Reviews Needed: OIG Finds Skilled Nursing Facilities Failing to Report and Investigate Incidents of Potential Abuse and Neglect

[06/14/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #5 – Effective Communication of Compliance Standards to Staff, Contractors and Volunteers

[06/10/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #4 – Screening Process for Positions With Discretionary Authority

[06/06/19]

CMS Finalizes New Regulations for Program of All-Inclusive Care for the Elderly (PACE) Organizations

[06/04/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #3 – Sufficient Resources and Authority

[05/29/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #2 – Assign Oversight Responsibility of Compliance Program

[05/22/19]

Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #1 – Policies and Procedures

[05/15/19]

CMS Ends Freeze on Nursing Home Five-Star Rating System

[03/13/19]

CMS Revises Guidance on Immediate Jeopardy and Creates New Surveyor Tools – Actions Needed to Prevent and Defend Skilled Nursing Immediate Jeopardy Citations

[03/07/19]

Expect Active Follow-Ups: OIG Finds State Survey Agencies Are Not Verifying Facilities’ Corrections of Deficiencies

[02/13/19]

Ohio Supreme Court Case: Nursing Facility Could Not Collect Deceased Husband’s Debt from Wife Under Ohio’s Necessaries Law

[01/29/19]

HHS Releases Updated Guidance on Health Industry Cybersecurity Practices

[01/24/19]

CMS Targets Inadequate Registered Nurse Staffing in Skilled Nursing Facilities – More Weekend Surveys and F-Tag Directive

[12/31/18]

Nursing Home Fine Upheld for Inadequately Addressing Sexual Interactions Between Cognitively Impaired Residents – Policy Reviews Needed

[12/13/18]

Countdown to Phase 3 – Skilled Nursing Facilities Need to Create a Compliance and Ethics Program

[11/29/18]

Selling Your Nonprofit Nursing Home? New York’s Attorney General Details Concerns About Sales of Nonprofit Nursing Homes

[11/13/18]

CMS Issues Final Interpretive Guidelines for the Conditions of Participation for Home Health Agencies

[09/06/18]

CMS Adds Survey Process for Reviewing Home Dialysis Services in Long-Term Care Facilities

[08/28/18]

CMS Issues Final Rule on FY 2019 Payment and Policy Changes for Skilled Nursing Facilities

[08/07/18]

CMS Updates Requirements to Reduce Legionella Risk in Health Care Facility Water Systems and Identifies Surveyor Expectations – Review of Policies and Procedures Required

[07/12/18]

Changes to the Estate, Gift and Wealth Transfer Tax Exemptions in the Tax Act of 2017

CMS Issues 18-Month Moratorium and Delays Enforcement of Some Phase 2 Requirements for Long-Term Care Facilities

[11/27/17]

CMS Issues Draft of Interpretive Guidelines for the Conditions of Participation for Home Health Agencies

[11/01/17]

Countdown to Phase II Compliance: The Facility Assessment for Long-Term Care Facilities – Review of Facility Resident Population and Resources Required

[08/22/17]

CMS Revises CMP Policies and Analytic Tool CMS Uses to Impose Fines – Opportunities Exist for Facilities to Reduce CMPs

[08/01/17]

CMS Issues Clarification of Notice Requirements to Long-Term Care Ombudsman when Resident Is Transferred or Discharged from Long-Term Care Facility – Review of Practices, Policies and Procedures Required

[07/24/17]

CMS Issues Requirement to Reduce Legionella Risk in Health Care Facility Water Systems – New Policies and Procedures Required

[07/17/17]

CMS Issues Guidance Suspending Enforcement of Penalties for Phase 2 Requirements and Revises F-Tags

[07/11/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 6

[02/06/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 5

[02/01/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 4

[01/30/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 3

[01/26/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 2

[01/20/17]

CMS Finalizes New Conditions of Participation for Home Health: Part 1

[01/17/17]

CMS Issues Guidance Suspending Enforcement of Rule Prohibiting Use of Pre-Dispute Binding Arbitration Agreements While Court Ordered Injunction Remains in Effect

[12/19/16]

Court Grants Preliminary Injunction in Favor of American Health Care Association’s Complaint Against CMS for Arbitration Provision Changes Contained in New Regulations

[11/07/16]

American Health Care Association Announces Complaint Against CMS for Arbitration Provision Changes in New Regulations

[10/18/16]

CMS Finalizes New Regulations for Facilities: Part 4

[10/14/16]

CMS Finalizes New Regulations for Facilities: Part 3

[10/13/16]

CMS Finalizes New Regulations for Facilities: Part 2

[10/10/16]

CMS Finalizes New Regulations for Facilities: Part 1

[10/07/16]

CMS Finalizes New Regulations for Facilities

[09/29/16]

CMS Issues Guidance on Protecting Resident Privacy and Prohibiting Abuse-Related Photographs and Recordings by Nursing Home Staff

[08/08/16]

Long-Term Care Facilities Face Compliance Deadline – Five Things to Know About the Mandatory Payroll Based Journal Reporting

[04/05/16]

National Healthcare Decisions Day – April 16, 2015

[04/13/15]

Business Succession: Passing and Not Dropping the Baton

Indiana Changing the Way Residents Will Obtain Medicaid Coverage Beginning June 1, 2014 – Part 4: Indiana Publishes Final Rule on Changes to Indiana’s Administrative Code

[05/19/14]

Indiana Changing the Way Residents Will Obtain Medicaid Coverage Beginning June 1, 2014 – Part 3

[04/24/14]

Indiana Changing the Way Residents Will Obtain Medicaid Coverage Beginning June 1, 2014 – Part 2

[04/18/14]

National Healthcare Decisions Day – April 16, 2014

[04/14/14]

Daughter Not Liable for Mother’s Skilled Nursing Facility Expenses Because She Had No Authority Over Finances or Access to Mother’s Finances

[02/04/14]

Indiana Changing the Way Indiana Residents Will Obtain Medicaid Coverage Beginning June 1, 2014 – Some Indiana Residents Need to Establish Certain Trusts to Maintain Benefits

[01/31/14]

A New Year – A Brief Look at 2014 Estate Gift and Wealth Transfer Tax Exemptions

[01/03/14]

$100,000 Individual Retirement Account Charitable Rollover Set to Expire on December 31, 2013

[12/20/13]

A New Way to Document Your Goals for End-of-Life Care and How You Want to Die – Indiana’s Physician Orders for Scope of Treatment Law

[12/04/13]

Filial Responsibility Law (Part 2) – Another Tool for Nursing Homes to Get Paid – Son Liable for Parents’ $104,276 Nursing Home Bill Under North Dakota Law

[11/02/13]

Indiana Case: Nursing Home Could Not Collect Wife’s Debt from Husband’s Estate under Doctrine of Necessaries

[06/28/13]

Indiana’s New Physician Orders for Scope of Treatment (“POST”) Law

[06/27/13]

Indiana Repeals Inheritance Tax

[05/08/13]

National Healthcare Decisions Day – April 16, 2013

[04/15/13]

Good News for Charities – American Taxpayer Relief Act of 2012 Revives $100,000 Individual Retirement Account Charitable Rollover and Provides a Limited Time Offer

[01/04/13]

$100,000 Individual Retirement Account Charitable Rollover Revived for 2012 and 2013 in the American Taxpayer Relief Act of 2012

[01/01/13]

Changes to the Estate Tax in the American Taxpayer Relief Act of 2012

[01/01/13]

Year-End 2012 Gift Opportunities

[12/01/12]

New Jersey Court Holds Daughter Who Signed Admission Agreement as “Responsible Party” Liable For Amount Due to Nursing Home for Her Failure to Use Mother’s Income and Resource to Pay Nursing Home

[06/04/12]

Indiana Medicaid Estate Recovery – UPDATE – Indiana Signs Contracts with Law Firms to Pursue Collection from Estates

[06/04/12]

New Vermont laws on abuse, neglect and exploitation of vulnerable adults residing in long term care facilities

[05/16/12]

Filial Responsibility Law – Another Tool for Nursing Homes to Get Paid – Son Liable for Mother’s $92,943 Nursing Home Bill Under Pennsylvania Law

[05/10/12]

National Health Care Decisions Day – April 16, 2012

[04/13/12]

Wife’s Nursing Home Debt Cannot Be Discharged in Bankruptcy

[04/13/12]

Michigan Begins Medicaid Estate Recovery

[07/08/11]

Indiana Medicaid Estate Recovery – Indiana Ready to Get More Aggressive?

[06/29/11]

Indiana Enacts Uniform Adult Guardianship and Protective Proceedings Act

[06/24/11]

Business Succession Passing and Not Dropping the Baton

[01/21/11]