June 23, 2026
Healthcare REITs, Hospitals, Nursing Homes: Status of State Legislative Efforts to Intensify Oversight of Healthcare Transactions
With only a handful of state legislatures still in session and most adjourned for the year, our review of state efforts to expand oversight of or impose restrictions on material changes in hospitals and healthcare…
May 21, 2026
CMS Proposal Pushes DPP Restrictions but Near-Term Impacts on Hospitals, Nursing Homes Still Limited Due to Grandfathering
CMS’s long-awaited proposed rule implementing the One Big Beautiful Bill’s (OBBB) restrictions on state directed payment programs (DPPs) pushes the envelope a bit further than the statute itself, particularly for hospitals [HCA, THC, CYH, UHS,…
April 5, 2026
SNFs, IRFs, IPFs: Proposed Increases in Range, But Future Risks Medicare Lurk for SNFs and IRFs [ENSG, PACS, SBRA, OHI, LTC, CTRE, EHC, SEM, UHS, ACHC]
FY27 Medicare reimbursement proposals for skilled nursing facilities [ENSG, PACS] and related REITs [SBRA, OHI, LTC, CTRE], inpatient rehab facilities (IRFs) [EHC, SEM, Kindred]and inpatient psych facilities (IPFs) [UHS, ACHC] were broadly in-line with our…
September 3, 2025
Nursing Homes & DOJ’s Shot Across the Bow [ENSG, PACS, WELL, OHI, SBRA, LTC]
Tuesday’s announcement by the DOJ to join a 2016 False Claims Act (FCA) whistleblower lawsuit against non-profit ProMedica Health System and its HCR ManorCare nursing homes may represent a new front in attacking long-term care…
August 1, 2025
Hospitals, LTCHs, SNFs: Thoughts on Medicare’s Final FY26 Inpatient Rate Rules
Medicare’s final FY26 payment regulations for inpatient hospitals [HCA, THC, CYH, ARDT, UHS, MPW, municipal bond-backed facilities], long-term care hospitals (LTCHs) [SEM, Kindred], and skilled nursing facilities (SNFs) [ENSG, PACS, Providence] with implications for their post-acute…
February 4, 2025
[ENSG, PACS, SBRA, OHI]: Potential Timing of the Nursing Home Staffing Rule’s Demise
With the briefing in a federal lawsuit having concluded and Congress on the hunt for legislative savings, the question is when, not if, CMS’s minimum nurse staffing rule is killed, eliminating the overhang and potential…
November 19, 2024
Healthcare Extenders in FY25 Spending Bill: What Is Likely, Unlikely or Toss-Up?
With likelihood growing that Congress focuses on emergency spending and a short-term continuing resolution funding the government into Q1 next year during this lame duck period, we expect that translates to Congress punting on nearly-annual,…
November 14, 2024
(ENSG, PACS, OHI, CTRE, SBRA) Nursing Home Relief from Minimum Staffing Rule Still Likely But as Part of FY25 Spending Bill
Key Takeaways: We still expect nursing homes and their post-acute care REIT landlords to secure a reprieve from the Biden CMS rule imposing minimum nurse staffing requirements on these long-term facilities. However, we see that…
October 14, 2024
Nursing Home Minimum Staffing Rule – Full Reprieve Near Term Unlikely, Potential for Smaller Relief
Key Takeaways: Nursing homes and their post-acute care REIT landlords have legal and legislative reasons to be hopeful about efforts to kill CMS’ minimum staffing rule, but we are skeptical they will secure a full…