High Screening May Lead to High Stakes for SNFs

Nelson Mullins Riley & Scarborough LLP

In the CY 2023 Physician Fee Schedule Final Rule (CMS-1770-F) Centers for Medicare & Medicaid Service (CMS) cracks down on the provider enrollment process. Specifically, CMS added Skilled Nursing Facilities (SNFs) to the “High” screening category. This new classification subjects SNFs to more frequent site visits and establishes a requirement to produce fingerprints of the SNFs 5% or greater direct or indirect owners. Further disclosure under an OIG exclusion check now applies to officers, directors, and managing organizations. SNFs will need to be mindful of the new reporting requirements when adding practice locations and undergoing a change in ownership. For a complete overview of these updates, read more in CR 12865.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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