On November 17, 2023, CMS published the final rule, Medicare and Medicaid Programs; Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities. In this final rule, CMS clarified that the term Managing Employee “includes, but is not limited to, a hospice or skilled nursing facility administrator and a hospice or skilled nursing facility medical director.”
In its response to comments related to the Ownership Transparency Rule, CMS indicated its belief that this revision, which was first published in its calendar 2024 Final Rule for Home Health Prospective Payment on November 13, 2023, was reflective of a stance it had held “for many years.”
In an early February MLN Connects Newsletter, CMS further clarified its expectation that skilled nursing facilities (SNFs) that have not reported their administrator and medical director should not wait until a revalidation request. Instead, they should update their provider enrollment as soon as possible for this information.
The senior living team at Forvis Mazars recommends SNFs gather the required information and immediately report their administrator and medical director as a Managing Employee as a change of information.
Stay tuned for more information on the Ownership Transparency Rule and make sure you receive timely updates by subscribing to our Long-Term Care & Senior Living FORsights.