The Centers for Medicare & Medicaid Services has proposed substantial Medicare enrollment and program integrity changes that could affect providers across the care continuum. Although included in the calendar year 2027 home health proposed rule, the provisions would apply broadly to Medicare providers and suppliers as CMS continues to take aim at waste, fraud, and abuse in the Medicare program. Join Monday’s Advocacy in Action at 10 a.m. for a review and Q&A of the proposed rules, where concerns lie, and action steps moving forward.
What You Need To Know
- CMS is proposing a new authority to revoke a provider’s or supplier’s enrollment if it deems the enrollment as presenting as high risk of fraud, waste, or abuse due to the provider’s or supplier’s location within a limited geographic area that has an excessive number of providers and suppliers.
- CMS is proposing revocation of enrollment if the provider or supplier - or any owner, managing employee or organization, officer, or director thereof - was convicted of a Federal or State misdemeanor related to sexual assault or financial misconduct within the past 10 years that CMS deems detrimental to the best interests of the Medicare program and its beneficiaries.
- CMS proposes making all enrollment revocations retroactive, generally to the date noncompliance began, which could increase repayment exposure.
- Providers subject to revocation would have 15 calendar days from the revocation letter to submit remaining claims, down from 60 days for most providers.
- New or expanded denial and revocation grounds would address billing practices, false or misleading enrollment information, certain misdemeanor convictions, high-risk geographic areas and violations of the 36-month change-in-majority-ownership rule.
- CMS also proposes broader definitions of managing employees and affiliations, new requirements for hospice reactivation and additional scrutiny of owners, managers and related entities.
What to Do
Members are highly encouraged to review LeadingAge’s full analysis of the proposed enrollment and revocation provisions. Join Advocacy in Action Monday, July 20, at 10 a.m. Katy Barnett of LeadingAge will discuss the proposals with LeadingAge Ohio members and answer questions about their potential impact. Top You Asked: Are Risk-Based Surveys expected to continue?
We Answered: Yes. The Centers for Medicare and Medicaid Services (CMS) has indicated that it intends to expand the use of Risk-Based Surveys (RBS) beyond the current pilot, with additional eligibility criteria expected to be released in the coming months.
Evan Shulman, Director of the Division of Nursing Homes at the Centers for Medicare & Medicaid Services (CMS), has shared that approximately 10% of skilled nursing facilities could ultimately qualify for a Risk-Based Survey. While CMS has not yet released the final qualifying criteria, facilities that consistently demonstrate strong performance, such as higher Five-Star ratings, strong staffing, fewer hospitalizations, no history of resident harm or abuse, successful compliance with required data submissions, and no failed schizophrenia audits, are expected to be among those eligible.
It is important to remember that a Risk-Based Survey can be expanded into a full standard survey if surveyors identify concerns during the inspection. Complaint investigations will also continue to be conducted separately and are not replaced by the Risk-Based Survey process.
According to CMS, the goal of the Risk-Based Survey initiative is to better align limited survey resources with resident risk. By conducting shorter, focused surveys in consistently high-performing facilities, survey agencies can dedicate more time and resources to nursing homes where residents may be at greater risk for poor outcomes. LeadingAge Ohio will keep members informed as CMS releases official updates and additional guidance. Top LeadingAge Ohio is excited to announce the launch of a retirement plan solution created exclusively for our members. Designed for organizations sponsoring either a 401(k) or 403(b) retirement plan—as well as those exploring the addition of a retirement plan for the first time—this new solution provides access to the advantages of a pooled employer plan, helping organizations simplify retirement plan administration, reduce fiduciary responsibilities, leverage economies of scale that can help reduce retirement plan costs, and support employees in preparing for retirement.
Whether you’re evaluating your current retirement plan, considering a change, or looking to establish a retirement plan for the first time, this solution offers a modern, streamlined approach designed to meet the unique needs of our members.
Learn More
Join us for an informational webinar on August 4, where we’ll introduce the program, explain how it works, and highlight the benefits available to LeadingAge Ohio members. Members attending the LeadingAge Ohio Annual Conference at the end of August will also have the opportunity to schedule one-on-one meetings to discuss their organization’s retirement plan needs and determine whether this new solution is the right fit. New ideas. Practical solutions. Meaningful connections. The 2026 LeadingAge Ohio Annual Conference & Trade Show brings together aging services professionals for three days of education designed to help organizations thrive in a rapidly changing environment.
From artificial intelligence and workforce strategies to regulatory updates, leadership, quality improvement, and person-centered care, this year's sessions offer timely insights you can put into practice right away. Whether you're looking to solve today's challenges or prepare for tomorrow's opportunities, you'll find inspiration, innovation, and a community of peers ready to share ideas.
Join us this August and discover what's next for aging services. The LeadingAge Ohio Political Action Committee (PAC) invites members, partners, and guests to spend Monday, September 28, 2026, at the Golf Club of Dublin for a day on the green that makes a difference.
More than just a round of golf, the annual PAC Outing combines spirited competition, camaraderie, and the chance to connect with colleagues and partners, all while enjoying a beautiful course setting. Every swing supports LeadingAge Ohio’s advocacy, ensuring older Ohioans and the professionals who serve them have a strong voice at the statehouse.
Registration opens at 9 a.m. with a 10 a.m. shotgun start. Both foursomes and individual golfers are welcome, and spots are available through Friday, September 25. Sponsorships are also open for those who want to further champion the PAC’s mission.
View full event details and register. For questions regarding sponsorship, please contact Corey Markham, Director of Education and Business Development, at cmarkham@leadingageohio.org.
Please note that contributions to Political Action Committees must be made by individuals, partnerships, or LLCs, not corporations, and are not tax-deductible. All contributions are voluntary and will not influence membership standing or benefits. There’s always something happening at LeadingAge Ohio. View upcoming events and mark your calendar today.
- July 16, 1 p.m. - 2026 Reimbursement Collaborative: Maximizing Opportunity in a Changing Environment
- July 20, 10 a.m. - Advocacy in Action
- July 23, 2:30 p.m. - DON Networking Meeting
- July 28, 9:30 a.m. - SNF/AL Clinical Operations Subcommittee Meeting
- August 4, 10 a.m. - Discover LeadingAge Ohio’s New Retirement Plan Solution
- August 4, 1 p.m. - Membership Committee
- August 6, 9 a.m. - Budget and Finance Committee Meeting
- August 6, 10 a.m. - Advocacy Committee Meeting
- August 24, 9 a.m. - Hospice Pre-Conference Sessions
- August 25-27, 2026 - Annual Conference & Trade Show
Top Join more than 1000 of your LeadingAge peers for our National Policy Pulse calls where we keep members equipped to navigate the ever-changing arena of aging services national policy. The calls are on Mondays at 3:30 p.m. If you’re interested in signing up for these members-only calls, please sign up using the link on our National Policy Pulse webpage. Join over 6,000 changemakers from across the aging services sector at the 2026 LeadingAge Annual Meeting, October 25–27, to connect, collaborate, and advance meaningful change for older adults and the communities we serve. Bring the changemakers on your team and in your network to join the conversation and help shape what's next for aging services. Bring changemakers from your team as our sector comes together at the LeadingAge Annual Meeting. Top Ohio ended fiscal year 2026 with General Revenue Fund spending approximately $778 million below budget estimates, according to the Office of Budget and Management's June financial report. Much of the underspending came from the Medicaid program, where state expenditures were $450 million below projections.
OBM attributed the Medicaid savings primarily to declining enrollment, with the program now serving approximately 2.8 million Ohioans, returning to pre-pandemic caseload levels following the completion of Medicaid eligibility redeterminations. Health and human services spending also finished the fiscal year below estimates.
Read the July 2026 Monthly Financial Report from the Office of Budget and Management. Ohio experienced one of the nation's steepest declines in Affordable Care Act (ACA) Marketplace enrollment this year, with enrollment falling by more than 160,000 people - a 32% decrease from February 2025 to February 2026, according to recently released federal data. Nationally, Marketplace enrollment declined about 13% over the same period.
Health policy experts attribute the decline largely to the expiration of enhanced federal premium subsidies that had lowered monthly insurance costs for many consumers, though federal officials have also cited efforts to reduce improper enrollments. The reduction in Marketplace coverage could have implications for providers as more Ohioans become uninsured or seek coverage through other programs. Read the original Columbus Dispatch article. The University of Cincinnati and UC Health have launched the Center for Alzheimer's and Neurodegenerative Diseases Research (CANDR), a new initiative focused on advancing dementia research, expanding access to clinical trials, and improving brain health.
The center will bring together researchers and clinicians to study Alzheimer's disease and other forms of dementia, with an emphasis on how vascular health and lifestyle factors influence cognitive decline. One of its first projects will follow 10,000 young adults across Ohio, Northern Kentucky, and West Virginia to better understand brain health over time and identify opportunities to reduce dementia risk earlier in life.
University leaders say the center will strengthen collaboration, accelerate research, and expand access to innovative care for individuals and families affected by Alzheimer's disease. Read the original UC release news article. The Ohio State University has established a university-wide Institute on Aging that will bring together more than 50 faculty members across 13 colleges to advance aging-related research, care and workforce development. The institute will focus on interdisciplinary research, clinical trials, caregiver support, disease prevention, data integration and partnerships with health care systems and community organizations, with the goal of improving health and quality of life across the lifespan. Read the original Ohio State News article. Top The Centers for Medicare & Medicaid Services has revised the Quality Measures domain rating thresholds used in the Nursing Home Five-Star Quality Rating System. The new thresholds take effect with the July 29 quarterly Care Compare refresh and may affect nursing homes’ Quality Measures and overall star ratings. Review LeadingAge’s summary of the updated thresholds. Top This week, the Ohio Department of Medicaid (ODM) posted July reimbursement rates to its website. These rates reflect updated quality incentive payment scores, as well as the proportion of the case mix index that is derived from PDPM data. Notably:
- The 25th percentile threshold for quality incentive payments increased to 35.75 points, out of a total range of up to 49.5 points.
- The price per quality point is set to $1.03.
- Beginning 7/1/2026, two-thirds of the case mix score is derived from PDPM scoring, adjusted for budget neutrality.
Members are encouraged to review rates to ensure they align with internal data tracking. Providers may request a rate reconsideration if they believe there were errors made in Medicaid’s calculations. Questions may be directed to Stephanie DeWees at sdewees@leadingageohio.org or Susan Wallace at swallace@leadingageohio.org. According to State Operations Manual, F880, facilities must be able to demonstrate its measures to minimize the risk of Legionella and other opportunistic pathogens in building water systems such as by having a documented water management program. Water management must be based on nationally accepted standards (e.g., ASHRAE (formerly the American Society of Heating, Refrigerating, and Air Conditioning Engineers), CDC, U.S. Environmental Protection Agency or EPA) and include an assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g., Pseudomonas, Acinetobacter) could grow and spread.
Resources are available to develop and implement a water management program, such as:
- The ASHRAE Standard 188 - Legionellosis: Risk Management for Building Water Systems.
- The CDC toolkit to facilitate implementation of the ASHRAE Standard titled Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings: A Practical Guide to Implementing Industry Standards; and
- The EPA's Technologies for Legionella Control in Premise Plumbing Systems: Scientific Literature Review.
The Long-Term Care Survey Process instructs surveyors, through interviews, to determine whether the facility has assessed (e.g., description of the building water systems using text and flow diagrams) where Legionella and other opportunistic waterborne pathogens can grow and spread. CMS proposes removing 638 additional procedures from the inpatient-only list in 2027, allowing more surgeries to be performed in outpatient settings. For people with traditional Medicare, an outpatient procedure would not count toward the three-day inpatient hospital stay generally required for Medicare-covered skilled nursing facility care, potentially leaving some without affordable post-acute services. Providers should prepare for continued changes in hospital discharge patterns and review LeadingAge’s analysis of the proposal. Questions about coding the Minimum Data Set can be difficult to resolve. The Ohio Resident Assessment Instrument coordinator’s Question of the Month provides answers to common coding questions and gives providers an opportunity to submit questions for future guidance. The July 2026 Question of the Month document is attached.
GG0130, Self-Care, and GG0170, Mobility Admission
Question: A resident was admitted Dec. 10, 2025. A five-day Prospective Payment System Minimum Data Set assessment was scheduled with a late assessment reference date of Dec. 24, 2025. Therapy and nursing completed Section GG assessments on Dec. 10, 11 and 12.
Because the assessments were completed during the first three days of the resident’s Medicare stay, may the facility use them to complete GG0130, Self-Care, and GG0170, Mobility admission items? Or should the items be coded using information from the look-back period associated with the late assessment reference date?
Answer: The facility may use the assessments completed during the first three days of the Medicare Part A stay. For residents in a Medicare Part A stay, the Section GG admission assessment period is the first three days of the stay, beginning with the date entered in A2400B, Start of Most Recent Medicare Stay.
Facilities should note that if the late assessment reference date was not set while the resident was still in the Medicare Part A stay, the assessment may not be completed.
H0100, Appliances
Question: Should a rectal tube be coded in H0100, Appliances? If so, which item should be used? How should bowel continence be coded when the rectal tube was present throughout the entire seven-day look-back period?
Answer: Rectal tubes and fecal bags are not coded on the MDS. If the rectal tube was present throughout the entire look-back period, code H0400, Bowel Continence, as 9, not rated.
M1200E, Pressure Ulcer/Injury Care
Question: May pressure ulcer treatment provided at an outside wound clinic during the seven-day look-back period be coded in M1200E, Pressure Ulcer/Injury Care?
Answer: Yes. An intervention may be coded on the MDS when it was performed outside the facility, including at a wound clinic, when the treatment occurred after admission and within the look-back period.
The facility must have verifiable documentation, such as physician orders, treatment records or clinic notes.
Receive the Question of the Month
Organizations may add MDS coordinators, social services directors, dietary managers and other staff involved in MDS coding to the monthly distribution list. To subscribe, email Cheryl Moya and use “Question of the Month” in the subject line. Include the subscriber’s name, title, email address and facility name in the message.
Questions for a future edition may be submitted to the same email address with “Question of the Month” in the subject line. Top Join LeadingAge for the next LPC Member Network meeting on Thursday, July 30 at 2 p.m. for a fascinating discussion on some of the disparate and emerging research studies that focus on LPCs. The panel will feature Tom Akins, LeadingAge North Carolina’s President and CEO, as well as Karan Shah, Data Analyst from the National Investment Center, among others. All LeadingAge provider members are welcome. To receive the invitation, email Dee at dpekruhn@leadingage.org. Top LeadingAge Ohio holds valuable education webinars and in-person events throughout the year. Opportunities are added weekly. See the complete Schedule of Events. Chronic constipation is a prevalent symptom in older adults. Up to 20 percent of community-dwelling older adults and 74 percent of nursing home residents use laxatives on a daily basis. Age, immobility, comorbid conditions, polypharmacy, eating less and inadequate hydration are all risk factors for constipation.
This month's DYK article, from LeadingAge Ohio Partner HealthDirect Pharmarcy Services, addresses chronic constipation management, reviews medical conditions and medications that can contribute to constipation, and provides a summary of recommendations for medication selection to treat constipation from recent guideline updates. The goal of treatment is to alleviate bowel-related symptoms that are bothersome to the patient. Top
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