Lexology March 4, 2024
Applicable Provider Types: Hospice; Home Health Agency
Is Your Entity in Compliance?
The Centers for Medicare & Medicaid Services (CMS) finalized and expanded its so-called 36-month rule with certain changes applicable to Medicare-enrolled hospices. As of Jan. 1, 2024, CMS generally prevents Medicare-enrolled hospices and home health agencies (HHAs) from undergoing a “change in majority ownership” within 36 months of the hospice’s or HHA’s initial enrollment in Medicare or its most recent change in majority ownership. A “change in majority ownership” means a change in more than 50% of the hospice’s or HHA’s direct ownership interests. Such a change may be triggered by acquisitions involving asset sales, stock transfers, consolidations or mergers that have the cumulative effect of changing more...
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