CMS Releases Skilled Nursing CHOW (and Ownership) Data

For the first time, the Centers for Medicare & Medicaid Services (CMS) has released data publicly on skilled nursing facility changes of ownership (CHOWs)). The data, which was released on April 20, 2022, includes information associated with CHOWs from 2016-2022. In its press release, CMS stated that the goal is to “promote competition and transparency in our nation’s health care system that can improve the safety and quality of nursing homes and hospitals.”

The data was released in part to support President Joe Biden’s Executive Order on Promoting Competition and advance the Biden-Harris Administration’s goal of improving transparency around nursing facility ownership. In addition to the data release, the HHS Office of the Assistant Secretary for Planning and Evaluation will release a report analyzing the data and examining trends in changes of ownership since 2016.

The data is searchable in two sets, one titled “Skilled Nursing Facility Change of Ownership,” which includes the following information:

• Enrollment State – Buyer/Seller
• Provider Type – Buyer/Seller
• NPI – Buyer/Seller
• CCN – Buyer/Seller
• Organization Name – Buyer/Seller
• DBA – Buyer /Seller
• CHOW Type
• Effective Date of CHOW

The other set is titled “Skilled Nursing Facility Change of Ownership – Owner Information,” which is searchable by facility, entity, and other identifiers. The information is pulled from Medicare CHOW filings and; presumably it is not kept current when additional ownership updates are made only reflects ownership immediately after a CHOW has occurred. The data set includes the following information:

• Organization Name
• DBA Name
• Address
• First/Last Name
• Title of Individual
• Role (i.e., 5% or greater direct or indirect owner, managing employee, officer, director, etc.)
• Association Date
• Percentage Ownership

While Nursing Home Compare has made skilled nursing facility ownership information publicly available for some time, the information posted to the web site was much more limited and disclosed much less of the information collected in Medicare enrollment applications. We also note that the same data has also been released for hospitals, see here. Skilled nursing facility and hospital owners/operators should check the data to make themselves aware of the information now publicly available.

For more information, please contact Hedy Rubinger or Alex Foster.

The Arnall Golden Gregory Change of Ownership (CHOW) team leads all regulatory aspects of healthcare transactions for investors, operators, managers, capital partners, and developers of every size in all 50 states. The team streamlines the regulatory process so that clients close their transactions on or ahead of schedule. Whether obtaining licensure and Medicare/Medicaid approvals, structuring transactions to expedite closings, anticipating issues to minimize cash flow disruption, negotiating regulatory terms in deal documents, creatively resolving diligence issues, or advising on CHOW guidelines and compliance, the team provides extensive experience and practical solutions. To date, the CHOW team has served as primary regulatory counsel in transactions valued at more than $25 billion.​