Articles and Blogs

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

On November 21, 2024, the Centers for Medicare & Medicaid Services (“CMS”) issued revised guidance under QSO-25-09-ALL, updating Core Appendix Q of the State Operations Manual regarding findings of immediate jeopardy. These updates are intended to enhance transparency, standardize immediate jeopardy determinations and improve communication with providers, suppliers and laboratories. These revisions apply to... READ MORE

On December 13, 2024, the Centers for Medicare & Medicaid Services (“CMS”) continued revisions to its “Guidance for SNF Attachment on Form CMS-855A” (“Guidance”). The Guidance is CMS’s subregulatory advice and FAQs to skilled nursing facilities on the completion and submission of the new Form CMS-855A SNF Disclosures Attachment (“SNF Attachment”) for every skilled... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) provided additional details and information related to CMS provider enrollment site visits. On November 4, 2024, CMS issued a Quality and Safety Special Alert memo (“QSSAM”), “Clarification of CMS’ Provider Enrollment Visits (all providers and suppliers) and Specific Disclosure Requirements for SNFs and NFs.” CMS provides... READ MORE

On November 1, 2023, the Centers for Medicare & Medicaid Services (“CMS”) posted a pre-publication copy of the Calendar Year (“CY”) 2024 Home Health Prospective Payment System Rate Update Final Rule (“2024 Final Rule”), which has since been filed in the Federal Register. The 2024 Final Rule was the subject of a significant amount... READ MORE

On April 4, 2023, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“Proposed Rule”) that would update Medicare payment policies and rates for skilled nursing facilities (“SNFs”) under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for fiscal year 2024. The Proposed Rule also proposes changes and additions to the SNF... READ MORE