Articles and Blogs

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

On December 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date indefinitely to complete and submit the new Form CMS-855A Skilled Nursing Facility  (“SNF”) Disclosures Attachment for every SNF. In its Medicare Learning Network, 2025-12-11-MLNC, CMS formally announced that enrolled SNFs should continue collecting data on ownership, managerial, and related party... READ MORE

On July 17, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date to complete and submit the new Form CMS-855A SNF Disclosures Attachment for every Skilled Nursing Facility (“SNF”).  In its Medicare Learning Network, 2025-07-17-MLNC, CMS formally announced that enrolled SNFs should collect data on ownership, managerial and related party information and... READ MORE

On April 17, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date to complete and submit the new Form CMS-855A SNF Disclosures Attachment for every Skilled Nursing Facility (“SNF”). In its Medicare Learning Network, 2025-04-17-MLNC, CMS formally announced that enrolled skilled nursing facilities should collect data on ownership, managerial and related party... READ MORE