Jaya White Authors Bloomberg Law Article About New Ownership Disclosures for Skilled Nursing Facilities
Jaya White, national co-chair of the Quarles & Brady Long-Term Care and Clinical Laboratories practices, wrote a Bloomberg Law article that discussed how nursing homes should start preparing for new ownership disclosure requirements that stem from the Affordable Care Act. These requirements were announced in 2022 and order nursing homes to be more transparent regarding their ownership details.
An excerpt:
Long term care providers will face upcoming changes this year with expansive reporting obligations from the Centers for Medicare and Medicaid Services. The release of the updated Skilled Nursing Facility Attachment on the form CMS-855A [cms.gov] will push SNF providers, commonly known as nursing homes, to gather details about ownership information.
These rules, announced in 2022, stem from the Affordable Care Act, which established requirements for disclosure about nursing home ownership. This was in response to CMS’s growing concerns about whether nursing homes owned by private equity and other investment firms were providing quality care.
Additional disclosure requirements were part of a November 2023 CMS final rule [cms.gov], but the updated enrollment form with the new SNF attachment wasn’t issued until September 2024.
All SNF providers now have until May 1 to complete the updated disclosure requirements, but to accurately complete the SNF attachment will require providers to begin work immediately. CMS has issued sub-regulatory guidance [cms.gov] in the form of FAQs, which was updated frequently.