Lexology October 22, 2024
As we previously reported, CMS issued a Final Rule implementing certain requirements in the Affordable Care Act regarding the disclosure of ownership, managerial and other information for Medicare and Medicaid participating nursing facilities. Most notable and complicated of these new requirements is the obligation to report additional disclosable parties (“ADP”) and the organizational structure of each ADP.
While the Final Rule went into effect on January 16, 2024, it allowed some breathing room for facilities, stating that Medicare skilled nursing facilities would not have to disclose this newly required data until the Form CMS-855A (i.e., the Medicare enrollment form) had been revised, and only upon initial enrollment, a change of ownership, or a revalidation. The time has now come for...
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