Articles and Blogs

Indiana has enacted House Enrolled Act 1277 (“HEA 1277”), a Medicaid reform law that significantly changes the state’s PathWays for Aging program and other long-term services and supports. While many provisions of this law took effect July 1, 2026, the transition of certain long-stay nursing facility residents from managed care to fee-for-service Medicaid will... READ MORE

The Trump administration continues to pursue regulatory reform initiatives across the health care sector. A proposed Centers for Medicare & Medicaid Services (“CMS”) rule affecting Medicare-participating providers, including skilled nursing facilities, is currently under review by the Office of Management and Budget, a key step before publication. The proposal appears consistent with prior CMS... READ MORE

The Indiana Department of Health (“IDOH”) has issued a second public comment notice regarding its proposed amendments to Indiana’s Residential Care Facility (“RCF”) regulations. The proposal, first published earlier this year, would significantly expand resident rights, incorporate federal Home and Community-Based Services (“HCBS”) concepts into Indiana assisted living regulations and establish a new eviction... READ MORE

The Wisconsin Division of Quality Assurance (“DQA” or the “agency”) recently issued Wisconsin – 26-001, which addresses surveyor access to provider records during assisted living surveys. The guidance applies to Adult Family Homes (“AFHs”), Community-Based Residential Facilities (“CBRFs”) and Residential Care Apartment Complexes (“RCACs”). DQA’s memo confirms that providers utilizing electronic record systems must... READ MORE

On July 30, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued its final rule updating Medicare payment policies and rates for skilled nursing facilities (“SNFs”) under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for federal fiscal year (“FY”) 2027. The final rule also includes significant revisions to the Skilled Nursing... READ MORE

The Indiana Health Coverage Programs announced that it has received approval from the Centers for Medicare & Medicaid Services (“CMS”) to implement a statewide provider certification and enrollment moratorium for numerous Home- and Community-Based Services (“HCBS”) 1915(c) waiver providers. The moratorium becomes effective August 1, 2026, and initially will remain in effect for six... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) has announced the nationwide implementation of a new Risk-Based Survey (“RBS”) process for qualifying nursing homes beginning September 8, 2026. CMS Memorandum QSO-26-14-NH explains that the RBS is intended to allow State Survey Agencies (“SAs”) to use fewer survey resources at higher-performing facilities and redirect resources... READ MORE

The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently issued Advisory Opinion 26-15 addressing a subscription-based referral management software platform used during hospital discharge planning. OIG concluded that, under the facts presented, the arrangement could generate prohibited remuneration under the Federal Anti-Kickback Statute (“AKS”) because providers paying subscription fees... READ MORE

The Indiana Department of Health (“IDOH”) published proposed amendments to the Residential Care Facility (“RCF”) regulations at 410 IAC 16.2-5 governing resident rights, residency agreements and involuntary resident evictions. The proposal represents one of the most significant updates to Indiana’s assisted living regulatory framework in recent years and is intended to align Indiana’s rules... READ MORE

Effective January 1, 2026, the Centers for Medicare & Medicaid Services (“CMS”) implemented significant changes to the accreditation and enrollment framework for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers through the CY 2026 Home Health Prospective Payment System Final Rule (“Final Rule”). CMS adopted these changes in response to what it describes... READ MORE