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Bond’s health care and long term care practice groups want to ensure you’re ahead of the curve on a compliance requirement that will affect the nation’s skilled nursing facilities and, potentially, the organizations they work with.

The Centers for Medicare and Medicaid Services (CMS) substantially updated Form 8555A, as of Oct. 1, 2024, which has triggered numerous new requirements that must be satisfied by May 1, 2025 – a deadline just weeks away. CMS calls for enhanced reporting of nursing homes’ ownership, governance and managerial controls – and CMS calls for data on so-called Additional Disclosable Parties (ADPs) that includes certain contractors. The changes affect entities enrolling in Medicare and Medicaid, revalidating, submitting changes or navigating changes of ownership. The disclosure process is designed in part so that CMS can learn more about parties that exercise control or provide significant services to facilities – including board members, certain trustees and managing employees. SNFs must also diagram where they fit in vis-à-vis associated entities, and delineate levels of ownership and control.

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