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October 21, 2021

Pre-Dispute Arbitration Agreements with Long-Term Care Residents Can Be Regulated by CMS

The Eighth Circuit recently upheld CMS’ requirements regulating pre-dispute arbitration agreements between residents and long-term care (LTC) facilities paid by Medicare and Medicaid. CMS had revised the requirements in 2019, including by lifting its prohibition on pre-dispute binding arbitration agreements as a condition of participation for LTC facilities paid by Medicare and Medicaid. The Eighth Circuit decided, in part, that CMS's rule did not violate the Federal Arbitration Act, including because the revised conditions include terms that improved the transparency of arbitration agreements and proceedings in LTC facilities.