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Jessica Sonpal is special counsel in the Governmental Practice in the firm's New York office, focusing on healthcare issues.

On April 12, 2023, the Centers for Medicare and Medicaid Services (“CMS”) released a final rule updating key regulations pertaining to Programs of All-Inclusive Care for the Elderly (“PACE”) (the “Final Rule”). Overall, these changes, summarized below, will offer significant administrative and operational flexibilities. Except as otherwise noted, the requirements of the Final Rule are effective January 1, 2024.

Continue Reading CMS Releases CY2024 Final Rule for PACE Organizations

On February 15, 2023, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would require nursing homes enrolled in Medicare and Medicaid to disclose new information about their ownership and management structures. If finalized, the rule would require nursing homes to disclose any ties to private equity companies or real estate investment trusts (REITs) (defined below), as well as the names and information of individuals and entities that provide certain administrative, management or consulting services.

Continue Reading CMS Issues Proposed Rule Requiring Nursing Homes to Disclose Additional Ownership Information, Including Ties to Private Equity and REITS

On January 31, 2023, the New York State Office of the Medicaid Inspector General (OMIG) released three guidance documents to assist Medicaid providers in meeting the requirements of recently adopted regulations governing (i) the implementation and maintenance of an effective compliance program for certain providers; (ii) Medicaid managed care fraud, waste and abuse prevention programs; and (iii) OMIG’s Self-Disclosure Program for overpayments.

Continue Reading Attention New York Medicaid Providers: It’s Time to Upgrade Your Compliance Program