Nursing Home News 2025Dec18

Kierstin Reed • December 18, 2025

Audit Documentation

PLEASE NOTE:  MLTC reports that Myers & Stauffer is having some difficulty in acquiring the General Ledger reports as requested for supporting documentation of reported costs. This is a requirement that DHHS implemented in response to recent audit findings.



It is the expectation of the DHHS that any documentation of expenses/variances will be supported as requested. Please refer to regulation 471 NAC 45-010 Audits (below). Failure to provide proper documentation will lead to removal of the unsupported costs. 


45.010. AUDITS. The Department will perform at least one initial desk audit and may perform subsequent desk audits or a periodic field audit of each cost report. Selection of subsequent desk audits and field audits will be made as determined necessary by the Department to maintain the integrity of the Nebraska Medical Assistance Program. The Department may retain an outside independent public accounting firm, licensed to do business in Nebraska or the state where the financial records are maintained, to perform the audits. Audit reports must be completed on all field audits and desk audits. All audit reports will be retained by the Department for at least three years following the completion and finalization of the audit. An initial desk audit will be completed on all cost reports. Care classification maximums and average base rate components are computed using audited data following the end of the Cost Report Period. Subsequent desk and field audits will not result in a revision of care classification maximums or average base rate components. All cost reports, including those previously desk audited but excluding those previously field audited, are subject to subsequent desk audits. The primary period or periods and subject or subjects to be desk-audited are indicated in a notification letter sent to the provider to initiate a subsequent desk audit. The provider must deliver copies of schedules, summaries, or other records requested by the Department as part of any desk audit. All cost reports, including those previously desk-audited but excluding those previously field-audited, are subject to field audit by the Department. The primary period or periods to be field-audited are indicated in a confirmation letter, which is mailed to the facility before the start of the field work. A field audit may be expanded to include any period otherwise open for field audit. The scope of each field audit will be determined by the Department. The provider must deliver to the site of the field audit, or an alternative site agreed to by the provider and the Department, any records requested by the Department as part of a field audit.

CMS Shifts Service-Level MA Data Collection to a Voluntary Pilot. On December 16, a CMS memorandum answered our question of when a new Medicare Advantage data collection initiative would be implemented by outlining its decision to roll out this required data collection first as a voluntary pilot in 2026 and then to all plans sometime in the future. In September, the Centers for Medicare and Medicaid Services (CMS) finalized with approval from the Office of Management and Budget (OMB) a requirement for Medicare Advantage (MA)plans to report service-level data regarding their initial determinations and appeals related to both coverage and claims payment decisions. At the time that it was finalized, the implementation year was left blank. Although CMS suggests that this approach is to basically work out any kinks before a full-scale implementation, LeadingAge and other provider organizations question whether this is another step in CMS rolling back MA requirements that support MA plan compliance with and accountability for following Medicare regulations and as such, may never be implemented fully. LeadingAge felt this was an important policy victory when this data collection was finalized as CMS adopted many of our recommendations on what data elements should be collected. This data if collected on all MA plans could provide a comprehensive picture across plans of their prior authorization and payment denial patterns and evidence to point to where future reforms to MA plan practices should focus.


5 Star Reports: After a slight delay in reporting by CMS, SNF data has become available to update the latest 5 Star Reports. Your 5 Star Analysis Report will soon be available in the LeadingAge Report Portal. For those with multiple providers, reports will be sent to you by the end of the week. With the new SNF data, the MDS QMs and staffing data are from 2025Q2, the claims QMs are using 2025Q1, while the QRP QMs vary in the measure period depending on the QM. 


SMK Medical 2026 QAPI Self-Audit flipbook. The QAPI Self-Audit Calendar provides a structured, month-by-month approach to self-auditing your facility’s compliance with the most frequently cited F-tags. Dr. Demetrius Kirk and the SMK Medical team are providing this complimentary resource for LeadingAge Nebraska members. Access here.


Seeking Feedback on Long-Stay Antipsychotics Measure. LeadingAge is seeking feedback on the impact of the long-stay antipsychotics quality measure on Nursing Home Care Compare. This measure provides information on rates of antipsychotic usage in nursing homes and is utilized in the Five Star Quality Rating System. LeadingAge is a member of Project PAUSE, a coalition advocating for changes to the quality measure due to the relative failure of the measure to distinguish between appropriate and inappropriate antipsychotic usage and we would like your feedback. What has been the impact of this quality measure in your nursing home? Have your star ratings suffered, and what has been the impact of that? Is your nursing home more reluctant to admit potential residents who are already prescribed antipsychotics? Have you felt pressured to deprescribe for residents who were appropriately prescribed antipsychotics? Please share your input by emailing Jodi Eyigor jeyigor@leadingage.org. Note that we will not share any identifying information – we are simply looking for concrete examples of the impact of this measure.


Measures Under Consideration (MUC) List 2025 is Out. The Measures Under Consideration (MUC) List for 2025 was released on December 15. This list, released annually by December 1 and delayed this year by the federal government shutdown, details quality measures currently under consideration for the Centers for Medicare & Medicaid Services (CMS) various quality programs. Among the 24 measures under consideration in 2025, there is one measure under consideration for the Home Health Quality Reporting Program (QRP), Skilled Nursing Facility (SNF) QRP, and SNF Value-Based Purchasing (VBP). This measure, Advance Care Planning, is under consideration for many of the quality programs and varies only slightly by setting. There are currently no measures under consideration for the Hospice QRP. Public listening sessions and public comments will take place in early January 2026. To view the measures and learn more, check out the CMS Measure Management Systems (MMS) Hub.


Supporting Documentation for POI:  Providers are reminded to submit supporting documentation for your plan of improvement to the dhhs.healthcarefacilities@nebraska.gov email address. Recently several providers have attached these documents in the iQIES system, which is incorrect. The state does not receive notification that these attachments are present and is unable to access them. 


Be on the lookout! Provider renewals for nursing homes will begin distribution in January. License renewals for long term care are due on March 31st

Here is your NATIONAL Nursing Home Weekly Recap

By Kierstin Reed • October 1, 2026
HUD Report Highlights BABA Implementation, Monitoring Issues. On September 10, the Department of Housing and Urban Development (HUD) published a report by its own oversight entity, the Office of the Inspector General (OIG), evaluating the agency’s implementation of Build America, Buy America (BABA) requirements throughout HUD programs. The Buy America Preference within BABA requires federal agencies to limit federal infrastructure spending unless the iron, steel, manufactured, and construction products used were domestically sourced in the U.S., which has proven infeasible for LeadingAge members developing new affordable housing units. The report, titled “HUD Needs to Improve its Monitoring of the Buy America Preference of the Build America, Buy America Act,” called out HUD’s lack of compliance monitoring for BABA; OIG recommends that HUD designate an official responsible for overseeing BABA implementation and consistency across HUD program offices. BABA is applicable to four HUD program offices, including the Office of Multifamily Housing Programs, which administers the Section 202 Supportive Housing for the Elderly program, as well as the Green and Resilient Retrofit Program (GRRP), both of which are subject to BABA requirements. LeadingAge continues to urge HUD and Congress to fully exempt affordable housing developments from the Buy America requirements because they are too difficult to execute and the original statute did not intend to BABA requirements to affordable housing. HUD Publishes LeadingAge-Driven Flexibilities on Emergency Call Systems. On September 10, the Department of Housing and Urban Development (HUD) published new guidance, driven by concerns shared by LeadingAge, to create more flexibility within emergency notifications system requirements for affordable senior housing providers. Previously, the agency required owners of certain HUD-assisted senior housing communities to operate emergency call systems in independent living units, which could be used by residents to call for aid in the case of an emergency, like a fall or a medical event. However, LeadingAge members consistently reported issues with the call systems, including residents misusing the systems and property insurance providers limiting whole-building coverage because of the perceived liability risk associated with the medical nature of the emergency notification devices and systems. Further, many residents reported to housing providers that they prefer to utilize personally-worn emergency devices and view the property call system as overreach by housing providers. In its new guidance, HUD makes the systems optional and encourages owners to conduct wellness checks instead, which many LeadingAge affordable housing providers already do. LeadingAge confirmed with HUD that the removal of the now optional emergency notification systems is a project-eligible expense. We applaud HUD for addressing the concerns of senior housing communities, and we will work with our membership to ensure the highest quality of housing for HUD-assisted residents. Here is your weekly Affordable Housing Weekly Recap.
By Kierstin Reed • October 1, 2026
LeadingAge and Hospice Advocates Meet with OMB and DEA on Final Teleprescribing Rule
By Kierstin Reed • October 1, 2026
Federal District Court Vacates Multiple Provisions of HHS' Section 504 Rule Relating to the Integration Mandate
By Kierstin Reed • October 1, 2026
Coalition Partners to Host Webinar on El Salvador TPS. As many LeadingAge members know firsthand, the future of Temporary Protected Status (TPS) is creating significant uncertainty for employees, employers, and communities across the country. Two LeadingAge coalition partners – WorkPermits.US and the American Business Immigration Coalition (ABIC) – will host a virtual webinar on Thursday, September 17 at 3p ET that will provide U.S. employers with critical updates regarding the status of work authorization for Salvadoran employees with TPS. As of September 9th, El Salvador TPS is still in place , pending the government's decision on whether to extend the program. Nonetheless, for employers, changes to TPS can have real consequences for workforce stability, employee retention, recruitment, and business operations. It is important for employers to understand what these changes mean, what responsibilities they have, and how they can support their employees with TPS. During the virtual webinar, expert panelists will cover compliance responsibilities, employer legal obligations, and actionable advocacy steps to protect essential workers. Register here if interested in this topic, and as always, reach out to Associate Director for Immigration Advancement Shane Myers if you have questions or concerns. Here is your weekly Workforce Weekly Recap
By Kierstin Reed • October 1, 2026
ICAP Respiratory Guidance Updates
By Kierstin Reed • October 1, 2026
LeadingAge Assisted Living Study Underway Participation is officially open for the 2026-2027 Assisted Living Salary & Benefits Study . Now in its 29th consecutive year, the national survey is conducted by HCS in cooperation with LeadingAge . Below is a brief overview on the study: Submission Deadline : November 9th Report Publication : January 2027 LeadingAge Participant Pricing: $190 (pre-paid) / $210 (billed) vs. $400 non-participant rate Questionnaire Download : www.hhcsinc.com Below is a full press release with survey links to share with members. Kindly confirm receipt. Thank you! 2026 HCS Assisted Living Salary & Benefits Study Underway Hospital & Healthcare Compensation Service (HCS) is conducting its annual Assisted Living Salary & Benefits Study and requests your participation. Assisted Living/Personal Care/Residential Care providers are invited to complete and submit the study questionnaire by November 9th. The national study is published by HCS in cooperation with LeadingAge . There is no cost to participate. Survey respondents receive a substantial discount, with options to purchase the final results for $190 (pre-paid) or $210 (billed), compared to the $400 non-participant rate. Questionnaires are available for download on the HCS website at: www.hhcsinc.com . The results will be published in January 2027. Last year’s Report contained data from 1,057 communities nationwide. The results cover salaries, bonuses, and hourly rates for 50 positions, with data reported regionally by bed-size, profit type, and revenue, as well as by state and CBSA. The report also covers 18 fringe benefits, including health/dental/vision insurance, PTO/time-off policies, 401(k) plans, and educational assistance, while also covering critical metrics like turnover rates, granted/budgeted salary increases, shift differentials, and sign-on bonuses. If you should have any questions, or find you need additional time beyond 11/9 to submit your data, please contact Rich Cioffe at rjcioffe@hhcsinc.com , (201) 405-0075, ext. 10. HCS publishes ten annual compensation studies. Nationally known, their reports are recognized as the standard for reliable, comprehensive, and affordable compensation data for healthcare. Thank you for your continued support! Here is your Life Plan Community Weekly Recap .
By Kierstin Reed • October 1, 2026
PBJ Submissions- CMS Releases “Non submitter list” CMS reached out last week with a list of nursing homes that have not yet registered to submit PBJ data through iQIES. We are pleased to report there are NO LeadingAge Nebraska Nursing Homes on this list. On August 17, all PBJ submissions transitioned to iQIES and FY 2026 Quarter 4 data, due on November 14, must be submitted through this system. Nursing homes must request access through iQIES and be approved by the Provider Security Official in order to submit data. This process can take weeks, especially if the Provider Security Official is no longer working at the nursing home and a new one must be registered. Nursing homes are encouraged to follow the steps outlined in the CMS memo MA Disenrollment of SNF Residents in the Spotlight The Center for Medicare Advocacy reports that nursing homes are disenrolling residents from their Medicare Advantage plans without their knowledge and that the Centers for Medicare and Medicaid Services (CMS) have long-standing guidance that reinforces that these changes should only be initiated by the beneficiary or their authorized representatives. LeadingAge reminds members that such disenrollment actions by nursing homes can result in survey tags and investigations for fraud and abuse, while also can have wide-ranging implications for the beneficiaries. More details can be found in this LeadingAge article including links to the two CMS memos that outline what is permitted and the required steps that must be taken if nursing homes opt to assist beneficiaries and families with these decisions. CMS Updates HAI Measure to Include Claims Data. The Centers for Medicare & Medicaid Services (CMS) released an update to the Skilled Nursing Facilities (SNF) Quality Reporting Program (QRP) measure technical specifications on September 24, re-specifying the Healthcare-Associated Infections (HAI) Requiring Hospitalization measure. This measure will now include Medicare Advantage (MA) encounter data in addition to the Medicare Fee-for-Service data that was already included in calculations. The measure specifications also include updates to risk adjustment based on the inclusion of this data. Read the updated specifications in the technical specification report, available in the Downloads section of the SNF QRP Measures and Technical Information page. New HUB Resource for Hospice Care in Nursing Homes. LeadingAge is incredibly excited to share our new resource to help providers better coordinate care for nursing home residents receiving hospice services, Hospice Care in Nursing Homes: A Shared Responsibility. The education resource reviews five sections, relationship and communication processes, regulation and reimbursement including regulatory co-management expectations, navigating complex scenarios, care coordination, and tools for building contracts, which were developed from a series of listening sessions with both hospice and nursing home members. LeadingAge Comments on Proposed Medicaid Provider Tax Rule On September 21, LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule , Medicaid Program; Amending the Indirect Hold Harmless Threshold of Health Care-Related Taxes. In our comments, we make the case that the proposed rule extends CMS’ obligation to implement section 71115 of 2025’s HR 1, which modifies Medicaid health care-related (provider) tax rules, beyond the statutory text in key ways. LeadingAge urges CMS to realign its rulemaking in a manner that minimizes burden and financial exposure for both providers and states. Upon release of the proposed rule, we provided this article , touching on the relevant provisions in the rule. We dig deeper and urge CMS restraint in five key areas in our comments .
By Kierstin Reed • October 1, 2026
 FRIENDS OF LEADINGAGE NEBRASKA PAC - We need your support!
By Kierstin Reed • September 24, 2026
HUD Report Highlights BABA Implementation, Monitoring Issues. On September 10, the Department of Housing and Urban Development (HUD) published a report by its own oversight entity, the Office of the Inspector General (OIG), evaluating the agency’s implementation of Build America, Buy America (BABA) requirements throughout HUD programs. The Buy America Preference within BABA requires federal agencies to limit federal infrastructure spending unless the iron, steel, manufactured, and construction products used were domestically sourced in the U.S., which has proven infeasible for LeadingAge members developing new affordable housing units. The report, titled “HUD Needs to Improve its Monitoring of the Buy America Preference of the Build America, Buy America Act,” called out HUD’s lack of compliance monitoring for BABA; OIG recommends that HUD designate an official responsible for overseeing BABA implementation and consistency across HUD program offices. BABA is applicable to four HUD program offices, including the Office of Multifamily Housing Programs, which administers the Section 202 Supportive Housing for the Elderly program, as well as the Green and Resilient Retrofit Program (GRRP), both of which are subject to BABA requirements. LeadingAge continues to urge HUD and Congress to fully exempt affordable housing developments from the Buy America requirements because they are too difficult to execute and the original statute did not intend to BABA requirements to affordable housing. HUD Publishes LeadingAge-Driven Flexibilities on Emergency Call Systems. On September 10, the Department of Housing and Urban Development (HUD) published new guidance, driven by concerns shared by LeadingAge, to create more flexibility within emergency notifications system requirements for affordable senior housing providers. Previously, the agency required owners of certain HUD-assisted senior housing communities to operate emergency call systems in independent living units, which could be used by residents to call for aid in the case of an emergency, like a fall or a medical event. However, LeadingAge members consistently reported issues with the call systems, including residents misusing the systems and property insurance providers limiting whole-building coverage because of the perceived liability risk associated with the medical nature of the emergency notification devices and systems. Further, many residents reported to housing providers that they prefer to utilize personally-worn emergency devices and view the property call system as overreach by housing providers. In its new guidance, HUD makes the systems optional and encourages owners to conduct wellness checks instead, which many LeadingAge affordable housing providers already do. LeadingAge confirmed with HUD that the removal of the now optional emergency notification systems is a project-eligible expense. We applaud HUD for addressing the concerns of senior housing communities, and we will work with our membership to ensure the highest quality of housing for HUD-assisted residents. Here is your weekly Affordable Housing Weekly Recap.
By Kierstin Reed • September 24, 2026
CMS' Technical Error in Final FY27 Hospice Wage Index
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