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To Recuse or Not to Recuse: OGE Updates Guidance

Client Alert | 1 min read | 07.26.16

On July 26, 2016, the Office of Government Ethics issued a final rule updating the Standards of Ethical Conduct for Employees of the Executive Branch, subpart F, “Seeking Other Employment” (5 C.F.R. 2635), to clarify recusal requirements. Recusals are required when the scope of the federal employee’s duties has a “direct and predictable” effect on the financial interest of an entity with whom the employee is either negotiating prospective employment or with whom the employee has any agreement concerning prospective employment, and the final rule also adds a new section to implement the statutory notification requirements under section 17 of the STOCK Act, which applies to individuals required to file public financial disclosure reports.

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Client Alert | 5 min read | 05.16.24

CMS Finalizes Contested Rule on Nursing Home Staffing and Facility Assessments

On May 10, 2024, the Centers for Medicare & Medicaid Services (“CMS”) published a Final Rule that, for the first time, imposes national minimum nurse staffing requirements for nursing homes. Specifically, the standard adopted by CMS requires minimum staffing of 3.48 hours per resident day (“HPRD”), as discussed in more detail below. CMS estimates that the new requirements will cost facilities $43 billion over the next 10 years, which is more than the $40.6 billion cost that CMS estimated for Proposed Rule of 3.0 HPRD. Some industry sources estimate that less than 25% of nursing facilities across the country currently meet the full scope of staffing standards laid out in CMS’ Final Rule due to a myriad of factors including labor shortages and increasing wage pressures. Indeed, the impact and cost of these staffing requirements will vary significantly by state. For example, CMS reported that at least one state will need to increase certain staff by nearly 96% to meet the minimum standards, while other states already meet the requirements....

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