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

Effective October 1, 2024, the Centers for Medicare & Medicaid Services (“CMS”) introduced significant updates to the CMS-855A form, specifically requiring a new Skilled Nursing Facility (“SNF”) Attachment for every SNF. These changes, following the implementation of regulations finalized in November 2023, impact how SNFs disclose detailed ownership and management information. The adjustments stem... READ MORE

As skilled nursing facilities work and provide health care services after the May 11, 2023, end of the Public Health Emergency, questions and concerns about visitation at these facilities will likely continue to arise. The Centers for Medicare & Medicaid Services (“CMS”) recently released revisions and additional clarifications to prior CMS guidance on many... READ MORE

On January 30, 2023, the Biden Administration announced the COVID public health emergency (“PHE”) will expire and end on May 11, 2023. The end of the PHE has a significant impact on skilled nursing facilities (“SNFs”) as it ends the remaining regulatory blanket waivers, revisits resident Medicaid eligibility and changes many COVID regulations that... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) intends to increase its oversight and scrutiny of skilled nursing facilities in its Special Focus Facility (“SFF”) program. CMS is revising the SFF program to protect and improve the quality of care that residents living in these skilled nursing facilities receive. This action is being taken... READ MORE

This was another dynamic year for the health care industry and for health care real estate, which is demonstrating remarkable resiliency and innovative success in the face of unprecedented challenges. This article summarizes a number of key 2021 takeaways and trends that were discussed during our 2021 Health Care Real Estate Year in Review... READ MORE

The Department of Health and Human Services (“HHS”) recently released details about qualifying for its nursing home infection control distributions. Previously, on September 3, 2020, HHS announced the details of its $2 billion Provider Relief Fund (“PRF”) performance-based incentive payment distribution to nursing homes (“NH Incentive Payments”). “Nursing homes” refers to skilled nursing facilities... READ MORE

On August 25, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released over 200 pages of interim final regulations (the “Interim Final Regulations”) to clarify new enforcement requirements for nursing homes, add requirements for labs to report COVID-19 test results during the public health emergency and require nursing homes to test residents and... READ MORE

CMS recently issued an update of a memorandum entitled “COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers” (“Blanket Waiver Memo”) that announced additional blanket waivers for providers, including hospitals and skilled nursing facilities (“SNFs”) as a result of the COVID-19 public health emergency (“PHE”). The waivers have a retroactive effective date of March... READ MORE

Summary In a February 2019 report, No. A-01-17-00506, HHS Office of the Inspector General (“OIG”) determined that Medicare made Part B payments to ambulance suppliers for transportation services that were covered through the Medicare Part A payments to skilled nursing facilities (“SNF”) as part of consolidated billing requirements. With certain exceptions, the SNF Part... READ MORE