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SNF Off-Cycle CMS-855A Reporting Delayed to August 1, 2025

Mandatory Medicare reporting for skilled nursing facilities (“SNFs”) has been delayed to August 1, 2025, to the relief of many in the industry. As a reminder, the Centers for Medicare & Medicaid Services (“CMS”) required the...more

Proposed New Rules to Add Long-Term Care Safety Requirements in Georgia

The Georgia Department of Community Health (“DCH”) board recently introduced proposed updates to long-term care facility standards, impacting background check requirements, care models for at-risk youth, and staffing...more

Georgia Nursing Homes, Assisted Living Communities, and Other Provider Types Must Now Make Licensure Filings (Including for CHOWs)...

With few exceptions, licensed Georgia providers, including but not limited to, nursing homes, assisted living communities, personal care homes, hospices, home health agencies, and community living arrangements, will now file...more

CMS Releases Update to CMS-855A Enrollment Form With Significant Increase in Disclosure Requirements for SNFs

The Centers for Medicare & Medicaid Services (“CMS”) has issued an updated version of the Form CMS-855A that requires additional disclosures for skilled nursing facilities (“SNFs”). Effective October 1, 2024, the revised Form...more

Proposed Legislation Focuses on Private Equity and REITs in Healthcare

Efforts to draw attention to and, in some instances, dissuade private equity investment in healthcare have been on the rise. For example, in late 2023, the Centers for Medicare & Medicaid Services finalized a rule increasing...more

CMS Announces the Innovation in Behavioral Health Model

Overview - The Centers for Medicare & Medicaid Services (“CMS”) is launching a new model aimed at improving the quality of care and health outcomes for individuals with behavioral health (“BH”) problems. The model, announced...more

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

CMS Expands Access to Behavioral Health Outpatient Services

The Centers for Medicare & Medicaid Services (“CMS”) announced it is expanding access to behavioral health services for Medicare beneficiaries through intensive outpatient services coverage. In general, Medicare will cover...more

UPDATE: CMS Finalizes Hospice 36-Month Rule

The Centers for Medicare & Medicaid Services (“CMS”) has finalized 2024 home health rules to include application of the home health “36-month rule” to hospice providers. The revised rule will forbid any change in majority...more

Home Health & Hospice Quarterly - Q3

AGG’s Home Health & Hospice team publishes a quarterly newsletter covering legal and regulatory topics specific to the home and community-based healthcare industry. The fields of end-of-life and home healthcare present...more

CMS Proposes Expansion of 36-Month Rule to Include Hospice Providers

The Centers for Medicare & Medicaid Services (“CMS”) issued a Proposed Rule on July 10, 2023, that, if finalized, will revise the Medicare Provider Enrollment requirements to expand the current Home Health Agency (“HHA”)...more

Illinois Legislature Passes Bill to Increase Healthcare Transaction Oversight

The Illinois Legislature recently passed HB2222, new antitrust legislation that will require advance notice to the attorney general for “covered transactions” between healthcare facilities and healthcare provider entities. If...more

Nursing Home Ownership Affiliations Published on Nursing Home Care Compare

In another step in the years-long process of increasing transparency in the nursing home industry, the Centers for Medicare & Medicaid Services (“CMS”) has begun posting nursing home affiliations on Nursing Home Care Compare....more

CMS Announces Enhanced Oversight for New Hospices in Four States

Effective July 13, 2023, the Centers for Medicare & Medicaid Services (“CMS”) announced a period of enhanced oversight for new hospices in Arizona, California, Nevada, and Texas. According to the Medicare Learning Network...more

Home Health & Hospice Quarterly - Q2

AGG’s Home Health & Hospice team publishes a quarterly newsletter covering legal and regulatory topics specific to the home and community-based healthcare industry. The fields of end-of-life and home healthcare present...more

Home Health & Hospice Quarterly - Q1

AGG’s Home Health & Hospice team publishes a quarterly newsletter covering legal and regulatory topics specific to the home and community-based healthcare industry. The fields of end-of-life and home healthcare present...more

Owners of Home Health Agencies and Hospices Released for First Time

On April 20, 2023, the Centers for Medicare & Medicaid Services (“CMS”) publicly released data on home health and hospice agency ownership for the first time. The data is derived from self-reported information (primarily...more

Proposed Rule Highlights Continued Push by CMS for Skilled Nursing Facility Ownership Transparency

In recent years, the Biden administration and Congress have pushed for greater transparency in skilled nursing facility ownership. In an effort focused on increased ownership disclosures specifically related to private equity...more

Provider Relief Funding: Reporting Period 4 Closes Friday, March 31

Providers who received Provider Relief Funds (“Funds”) exceeding $10,000 in the aggregate between July 1 and December 31, 2021, are required to file reports on use of funds during Reporting Period 4. The Fund Reporting...more

Changes of Ownership: Georgia Department of Community Health Issues Revised Financial Stability Affidavit

Applicants for personal care home (“PCH”) and assisted living community (“ALC”) licenses in Georgia will now submit a revised financial stability affidavit with any initial or change of ownership application. The revised...more

Changes of Ownership: 60-Month Rule for New California Hospices?

California enacted a slew of hospice reforms in 2021, including a minimum one-year hospice license moratorium. However, 2022 has brought more changes. Assembly Bill 2673, which was initially introduced in early 2022 but...more

Reimbursement Deadline Approaching for the COVID-19 Prevention and Mitigation Assisted Living Communities and Personal Care Homes...

In a previous article, we discussed Georgia’s announcement to award over $217 million to eligible healthcare facilities as a result of the American Rescue Plan Act (“ARPA”), which was signed into law by Congress on March 11,...more

HHS Announces Additional Planning Grants for State Behavioral Health Clinics

An additional $15 million will be allocated to states for planning grants related to behavioral health clinics as announced on October 18, 2022, by the U.S. Department of Health and Human Services (“HHS”). This funding stems...more

Senior Housing and the Transition From Operator to Manager

Parties typically involved in the ownership or operation of a skilled nursing facility (“SNF”) or assisted living facility (“ALF”) include the property owner, operator/licensee, and management company. For a variety of...more

Push for Greater Nursing Home Ownership Transparency Continues With Introduction of the Linking Investors and Nursing Home Quality...

The nursing home industry has seen increased efforts by the federal government to enhance transparency, with a focus on ownership disclosures (both past and present ownership) of facilities enrolled in Medicare. The efforts...more

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