Skilled Nursing Facilities

Skilled Nursing Facilities (SNFs) are highly regulated healthcare entities faced with significant government scrutiny directed their way. Our attorneys have extensive experience assisting SNFs in a variety of matters including audit defense, compliance activities, regulatory issues and billing and reimbursement issues.

Given the numerous regulations facing SNFs, it is important for SNF providers to consult with attorneys with experience navigating this area.  We strive to offer our clients an individualized approach whereby we apply our experience and expertise in handling SNF matters to your unique situation in an effort to develop efficient and effective solutions.

Audit Defense Consulting

Our attorneys have helped SNFs defend third party payor audit findings, including defending Medicare audits.  Audits of SNF services often focus on issues related to the three day qualifying stay and whether the condition the patient was receiving treatment for was a condition being treated in the hospital setting.  Audit scrutiny may also target whether the services provided to the patient were “skilled” services, as well as the sufficiency of the therapy documentation.  SNF audit denials may also challenge the appropriateness of the Resource Utilization Group (RUG) assigned to the patient.  We have experience defending these and other audits denials.


Now more than ever, compliance is a key area for SNFs. While the OIG compliance guidance for nursing facilities has been available for years, the Affordable Care Act recently made compliance programs mandatory for SNFs. We understand the risks that SNFs face and can help SNFs develop a compliance program that will meet the new mandatory compliance requirements and serve to reduce risks associated with regulatory and billing compliance.

Some of the other areas in which our attorneys counsel SNFs include:

  • HIPAA compliance

  • Assistance with Medicare Conditions of Participation

  • State survey issues and corrective action plans

  • Assistance with reimbursement issues

  • Assistance with documentation issues

  • Advice on avoiding potential anti-kickback issues and other regulatory concerns

  • Medical director agreements and other relationships with physicians

  • Development of contractual relationships with Accountable Care Organizations and other integrated models of care