New Nursing Home Disclosure Requirements per Chapter 343 of the Acts of 2024 (pdf)
January 2026
MassHealth’s new Disclosure Form for nursing homes is a comprehensive reporting document designed to increase transparency regarding the ownership, management, and financial structure of long-term care facilities.
Based on regulatory updates and industry guidance from the Massachusetts Senior Care Association (MSCA), the key details of this form include:
- Purpose and Legislative Origin
- Implementation of New Law: The form is being implemented as part of the state’s response to Chapter 343 of the Acts of 2024 (the market review law), which was passed to provide greater oversight of healthcare transactions following the Steward Health Care crisis.
- Transparency Goals: It aims to give state agencies better visibility into for-profit nursing home structures, specifically those involving private equity firms, Real Estate Investment Trusts (REITs), and complex management service organizations.
- Implementation of New Law: The form is being implemented as part of the state’s response to Chapter 343 of the Acts of 2024 (the market review law), which was passed to provide greater oversight of healthcare transactions following the Steward Health Care crisis.
- Design and Pattern
- Medicare Alignment: The form is explicitly patterned after the Mandatory Medicare Provider Enrollment Off-Cycle Revalidation form (specifically CMS Form 855A). This alignment is intended to streamline reporting for facilities that already report similar data at the federal level.
- Coordinated Regulation: The disclosure requirements align with the Rate Year 2026 Medicaid nursing facility regulations and the Center for Health Information and Analysis (CHIA) regulation 957 CMR 7.00.5
- Information Collected
Facilities are required to disclose extensive data, including:- Ownership and Control: Details on all individuals or entities with a direct or indirect ownership interest of 5% or more.
- Related-Party Transactions: Financial arrangements with affiliated entities, such as realty companies (REITs), management companies, or consulting firms.
- Business Transactions: Significant transactions with subcontractors that exceed $25,000 over a 12-month period.
- Managing Employees: Identification of key personnel such as administrators, medical directors, and others with operational or managerial control.
- Criminal Convictions: Disclosure of any owners or managing employees who have been convicted of crimes related to health care programs.
- Filing Timeline
- Expected Start: While specific deadlines will be issued via a MassHealth Administrative Bulletin, the initial filing is anticipated to occur in the first quarter of calendar year 2026
Mandatory Requirement: Completion of this form is a condition of participation in the MassHealth program; failure to submit it accurately and on time can lead to penalties or termination of the facility’s provider agreement.homes.
957 CMR 5.00 — Health Care Claims, Case Mix and Charge Data Release Procedures (pdf)
957 CMR 5.00, 957 CMR 6.00, 957 CMR 7.00 — current vs. proposed (side-by-side)
This document provides a section-by-section comparison of the current CHIA regulations and the proposed amendments posted for public hearing (January 8, 2026).
Integrated Testimony for the Public Hearing on 957 CMR 7.00 (pdf)
Executive Summary: Dignity Alliance Massachusetts strongly supports the proposed amendments to 957 CMR 7.00. Facility-level cost reports, as currently structured, lack construct validity for evaluating the true economic performance of nursing home ownership entities. Without parent-company and related-party transparency, CHIA’s data collection risks validating an accounting fiction that systematically understates investor returns while overstating operating distress. The proposed amendments are necessary to restore analytic integrity, protect Medicaid funds, and enable meaningful correlation between financial practices and quality of care. This testimony integrates findings and arguments developed in published work on private equity extraction, long-term care economic justice, and digital governance in health and human services (Lomastro, 2025a; 2025d; 2025e; 2025h; 2025j). That body of work demonstrates that financial opacity and financially-driven efficiency narratives often function to concentrate control and accelerate capital extraction rather than improve care quality.
Financial Transparency Can Prevent the Next Long-Term Care Crisis
Op-Ed by James Lomastro, Dignity Alliance
Massachusetts has already seen what happens when healthcare systems are hollowed out by financial engineering. The Steward Health Care crisis did not begin with clinical failure. It began with asset stripping — real estate deals, debt loading, and management arrangements that drained operating hospitals of the resources needed to care for patients.
A similar risk now threatens our nursing homes. Today, nursing facilities submit cost reports that describe only what happens inside the licensed building. But many of the largest operators separate ownership into multiple companies: one that runs the facility, another that owns the real estate, and another that provides management services. Money flows out through rent and fees, while the nursing home itself reports “losses.”
When policymakers hear that Medicaid does not cover costs, they are often hearing only part of the story. The proposed amendments to 957 CMR 7.00, currently before the Center for Health Information and Analysis (CHIA), would finally require reporting from management companies and significant equity investors — the entities that actually control financial decisions. This is not bureaucratic overreach. It is basic accountability.
Some critics argue that expanded oversight will cost the state more money. But modern regulatory agencies already use automated tools to flag missing data, abnormal ratios, and financial patterns associated with distress. Oversight does not require massive new staffing; it requires smarter use of data we already collect.
What truly costs taxpayers is collapse.
Massachusetts has approximately 30,000 nursing facility residents. If even ten percent of beds were disrupted by financial failure, thousands of medically fragile residents would be displaced. Hospitals would absorb the shock through emergency admissions and prolonged emergency department boarding. Medicaid spending would spike. Families would scramble for placements. The state would face emergency management and stabilization costs. This is not speculation. We have seen this cycle before, both in nursing home bankruptcies and most recently in hospital system failures.
Financial transparency is not about punishing providers. It is about preventing crises before they reach residents, hospitals, and taxpayers. It allows regulators to identify unsustainable financial practices early, when intervention is still possible and care continuity can be preserved.
Good nursing homes — including nonprofit and mission-driven providers — benefit from transparency because it distinguishes responsible operators from those whose business models depend on extraction rather than care. Massachusetts can lead the nation by treating financial oversight as a public health tool. The proposed amendments to 957 CMR 7.00 should be adopted in their strongest form, and the data collected should be used to link financial practices with staffing and quality outcomes.
If we fail to act, we should not be surprised when the next healthcare crisis begins — not in emergency rooms, but quietly in corporate balance sheets, far from public view.