Revised Guidance for Long-Term Care Surveyors: Important Information Regarding Third-Party Guarantees of Payment

The Centers for Medicare & Medicaid Services (CMS) has issued Memo QSO-25-14-NH, “Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance the quality and oversight of the LTC survey process,” with an effective date of April 28, 2025. One key revision pertains to the admission, transfer, and discharge agreement. In the memo, CMS clarified guidance prohibiting admission agreements from containing language that requests or requires a third-party guarantee of payment, adding examples of non-compliance.…

Loper Bright and CMS Compliance in a Post-Chevron World

The latest Supreme Court term has been one of incredibly consequential decisions. Rulings regarding gun rights, immunity, and abortion access grabbed headlines for months. Yet, the most important ruling for the healthcare space writ large is the case of Loper Bright v. Raimondo, which involved regulations in the commercial fishing industry. What does a ruling about fishery regulation have to do with the Centers for Medicare and Medicaid Services (CMS)? In this situation, nearly everything.…

Why Healthcare Providers Need to Develop Organizational Intelligence, Part 4: Avoiding Ignorance

This article is the fourth in a multi-part series discussing the concepts of organizational intelligence and their impact on healthcare providers. You can read Part 1 here, Part 2 here, or Part 3 here. It is safe to say that any organization would prefer to be labeled intelligent rather than ignorant. When an organization fails to learn or adapt its culture to the people it serves, it is usually attributable to a systemic inability to acquire, process,…