22 unchanged sentences
Adverse determinations in civil legal proceedings or governmental investigations, whether currently asserted or arising in the future, could have a material adverse effect on our financial position, results of operations, and cash flows.
−Removed: Additionally, such proceedings and/or investigation can be a distraction to the business of our independent subsidiaries.
+Added: Additionally, such proceedings and/or investigations can be a distraction to the business of our independent subsidiaries.
We, on behalf of our independent subsidiaries, received a Civil Investigative Demand (CID) from the U.S.
15 unchanged sentences
In 2024, we entered into mediation with the involved parties and agreed to settle the civil case for $48.0 million.
−Removed: Following the finalization of the settlement documents and payment of the settlement funds, the qui tam complaint was dismissed and the matter was resolved.
+Added: Following the finalization of the settlement documents and payment of the settlement funds, the qui tam complaint was dismissed and the matter was fully resolved.
The settlement does not include admissions on the part of the Company or our independent subsidiaries, and we maintain that we have consistently complied with and continue to comply with all applicable State and Federal statutes (including but not limited to the FCA and the AKS).
9 unchanged sentences
Healthcare litigation (including class action litigation) is common and is filed based upon a wide variety of claims and theories.
−Removed: We and our independent subsidiaries have been subjected to, and/or are currently involved in, class action litigation alleging violations (alone or in combination) of state and federal wage and hour law related to the alleged failure to pay wages, to timely provide and authorize meal and rest breaks, and other such similar causes of action.
−Removed: Additionally, in July of 2024, two of our independent subsidiaries received a subpoena to produce documents related to alleged environmental matters from the United States’ Attorney’s office for the Western District of Washington.
−Removed: Our independent subsidiaries fully cooperated with the United States' Attorney’s office in response to the subpoena.
−Removed: We recently learned that the United States’ Attorney’s office for the Western District of Washington has declined to pursue further proceedings in connection with this subpoena.
−Removed: Although a state or other authority may pursue the subject matter of this inquiry, we do not believe that the ultimate resolution of this matter will have a material adverse effect on our business, cash flows, financial condition or results of operations.
+Added: We and our independent subsidiaries have been subjected to, and/or are currently involved in, class action litigation alleging violations (alone or in combination) of state and federal wage and hour law related to the alleged failure to pay wages, to timely provide and compensate meal and rest breaks, and other such similar causes of action.
We and our independent subsidiaries have been, and continue to be, subject to claims, findings and legal actions that arise in the ordinary course of the various businesses, including in connection with the delivery of healthcare and non-healthcare services.
8 unchanged sentences
We anticipate that these Reviews could increase in frequency in the future.
−Removed: As of March 31, 2025 and through the filing date of this report, 18 of our independent subsidiaries had multi-claim Reviews scheduled or in process.
−Removed: In June 2023, CMS announced a new nationwide audit, the “SNF 5-Claim Probe & Educate Review,” in which the Medicare Administrative Contractors will review five claims from each SNF to evaluate for claims compliance.
−Removed: In implementing this SNF 5-Claim Probe & Educate Review, CMS acknowledged that the increase in observed improper payments from 2021 to 2022 may have arisen from a “misunderstanding” by SNFs about how to appropriately bill for claims of service after October 1, 2019.
−Removed: All facilities that are not undergoing TPE reviews, or have not recently passed a TPE review, will be subject to the nationwide audit.
−Removed: MACs will complete only one round of probe-and-educate for each SNF, rather than the three rounds that typically occur in the TPE Program.
−Removed: Additionally, CMS’s education for each SNF will be individualized and based on observed claim review errors, with rationales for denial explained to the SNF on a claim-by-claim basis.
−Removed: This program will apply only to claims submitted after October 1, 2019, and will exclude claims containing a COVID-19 diagnosis.
+Added: As of June 30, 2025 and through the filing date of this report, 10 of our independent subsidiaries had multi-claim Reviews scheduled or in process.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.