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Sunday, September 7, 2025

U.S. CMS Finalizes Rule Requiring Nursing Facility Disclosure of ... - Sidley Austin LLP

On November 17, 2023, the U.S. Centers for Medicare & Medicaid Services (CMS or the Agency) published a final rule (the Final Rule) requiring the disclosure of certain ownership, managerial, and other information from Medicare skilled nursing facilities (SNFs) and Medicaid nursing facilities (collectively, Nursing Facilities) upon enrollment, renewal, reactivation, revalidation, change of ownership, and change of enrollment information. Effective January 16, 2024, the Final Rule implements portions of Section 6101 of the Affordable Care Act (ACA) and aligns with the Biden administration’s efforts to address concerns about the standard of care and quality of operations of Nursing Facilities. Ownership data reported by Nursing Facilities will be made publicly available within one year of submission. CMS stated its position that these new reporting requirements for Nursing Facilities are a condition of both participation and payment.

The final rule hews closely to the proposed rule, which was issued on February 15, 2023, and which we addressed here.

Ownership Reporting Requirements for Nursing Facilities

As finalized, the rule requires Nursing Facilities to report the following information:

  1. each member of the governing body of the facility, including the name, title, and period of service for each such member
  2. each person or entity who is an officer, director, member, partner, trustee, or managing employee of the facility, including the name, title, and period of service
  3. ...


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