Articles and Blogs

On July 15, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued the CY 2026 Hospital Outpatient Prospective Payment System (“OPPS”) and Ambulatory Surgical Center (“ASC”) Payment System proposed rule. The rule, as drafted, proposes updating the payment rates of both OPPS hospital rates and ASC rates by 2.4%, calculated via the respective... 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 November 27, 2024, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (“Final Rule”) updating the Medicare Conditions of Participation (“CoPs”) for hospitals subject to 42 CFR Part 482 and critical access hospitals (“CAHs”) subject to 42 CFR Part 485. These updates establish a progressive rollout of nationwide standards for both... READ MORE

On May 21, 2025, the Centers for Medicare & Medicaid Services (“CMS”) announced a substantial expansion of its Risk Adjustment Data Validation (“RADV”) audit program for all Medicare Advantage (“MA”) plans. Effective immediately, CMS will audit all eligible MA plans annually and aims to complete outstanding audits for prior payment years (“PY”) 2018-2024 by... READ MORE

On April 30, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the FFY 2026 Inpatient Prospective Payment System (“IPPS”) Proposed Rule (“Proposed Rule”) to update IPPS payment rates, change DSH payments, increase uncompensated care payments and request input on ways to streamline Medicare regulations and reduce provider burden. Increase to Payment Rates... 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

The Centers for Medicare & Medicaid Services (“CMS”) has given surveyors additional rules and updates to allow surveyors to assess and cite violations of the regulations on nursing homes with admission agreements that create prohibited third-party guarantee of resident payments. On November 18, 2024, the Quality, Safety & Oversight Group at CMS issued a memorandum entitled... READ MORE

On March 7, 2025, the Centers for Medicare & Medicaid Services (“CMS”) posted a memo dated March 10, 2025, that gives nursing homes and surveyors more time to prepare for implementation of new rules and updates to allow surveyors to add extra attention and increase oversight in nursing homes. On November 18, 2024, the... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) is reinforcing its emphasis on hospice quality of care and identifying fraud. On November 13, 2024, CMS issued a QSO Memo, “Ensuring Consistency in the Hospice Survey Process to Identify Quality of Care Concerns and Potential Fraud Referrals” (the “CMS Memo”), addressing the importance of consistency in... READ MORE

On December 31, 2024, the Centers for Medicare & Medicaid Services (“CMS”) released a memo titled “Long-Term Care (LTC) Facility Acute Respiratory Illness Reporting Requirements” (“Memo”) to state survey agency directors providing survey guidance related to requirements for long-term care reporting through the National Healthcare Safety Network (“NHSN”) as COVID-19 data reporting requirements ended... READ MORE