Illinois long-term care facilities (LTCFs) and supportive living facilities (SLFs) will face new Medicare cost reporting requirements beginning with their 2025 cost reports.
Key takeaways:
- New, stricter deadlines and limited extensions
Calendar year-end LTCFs and SLFs now share a single filing deadline of May 31, 2026. Late or incomplete filings can delay payments or trigger enforcement actions, and extensions will be granted only in limited circumstances. - Significantly expanded ownership and financial disclosure requirements
Operating companies, property/building companies, and management entities must now disclose full ownership details along with related-party relationships. SLFs face more reporting expansions than LTCFs, including new schedules covering detailed expenses, staffing, indirect cost allocation, capital assets, and related-party transactions. - New SLF reporting template and increased documentation burden
SLFs must use a new mandatory cost report form similar to the LTCF template, but requiring greater detail and more supporting documents. The HFS will not accept the older format.
LTCFs and supportive living facilities SLFs based in Illinois and filing their 2025 cost reports face new and different requirements for the reports. The Illinois Department of Healthcare and Family Services (HFS) recently announced changes to the Medicare cost reporting requirements for LTCFs and SLFs beginning with the 2025 cost reports.
Because the changes affect both the time required to complete the reports and the information required, LTCFs and SLFs need to carefully review the changes and update their processes. Facilities that miss the deadline or do not report the necessary data face suspension of payments, among other consequences.
Here are the changes and how the updates affect each type of facility:
LTCFs: What You Need to Know
- The filing deadline for calendar year-end providers is now May 31, 2026
Previously, LTCF and SLF reports were due on different days. Starting this year, the deadline for the 2025 cost reports for both calendar year-end LTCFs and SLFs is the same day: May 31, 2026. If your facility files a late or incomplete report, your payment may be delayed or face other enforcement actions.
LTCF and SLF providers that ask for an extension this year may be surprised by a rejection. The HFS plans to grant extensions only in limited circumstances.
- Expanded Ownership Disclosure Requirements
Previously, LTCFs and SLFs were only required to disclose ownership information for the operating company (OpCo). Starting with the 2025 cost reports, LTCFs and SLFs now must disclose significantly more information, requiring additional time and documentation to complete the report.
HFS now requires full ownership disclosure for the OpCo facility, any related property company (PropCo) or building company, and any related management company or office, where applicable. Facilities must also report all relevant entities, including related-party relationships and common ownership structures.
SLFs: What You Need to Know
The biggest change for the 2025 calendar reporting year for SLFs is the new reporting template, which is similar to the LTCF cost report and requires significantly more detail than the previous form. Older formats will not be accepted, so all SLFs must use the new cost report form, or the report will be rejected.
SLFs should set aside more time than in previous years to gather information and complete the forms, especially the expanded financial and operational reporting.
Here are the new documentation requirements for the 2025 cost reporting for SLFs:
- Expanded Schedules
To make reports more consistent across facilities, SLFs must now complete the following new and expanded schedules:
- Schedule V – Detailed Cost Center Expenses: This schedule aligns the facility’s general ledger with the new reporting requirements by providing more detailed expense categories and additional columns.
- Adjustment Detail Schedules: Creating a clear distinction between care-related and non-care-related costs, this schedule requires expanded documentation of adjustments.
- Schedule VII – Related Organizations and Compensation: SLFs must provide detailed disclosure of related party transactions and compensation.
- Schedule VIII – Indirect Cost Allocation: This schedule improves transparency and comparability by formally allocating overhead across cost centers.
- Schedules XI–XII – Capital and Asset Reporting: Facilities must include detailed reporting of buildings, improvements, equipment, leased assets, and depreciation. Additionally, all assets not used for supportive care must be separately identified.
- Balance Sheet and Equity Statement Enhancements: This schedule provides a standardized financial statement presentation to make balance sheets similar to audited financials.
- Schedule XVIII – Staffing and Salary Costs: With a focus on labor cost transparency, this schedule requires more detailed reporting of positions and wage categories.
- General Information Questionnaire: The HFS cost report form collects general information through structured responses and drop-down selections, including compliance- related confirmations and organizational details.
- Additional Supporting Documentation
The new SLF template places greater importance on supporting documentation and audit readiness, requiring the following:
- Real Estate Tax Statements: SLFs will complete a worksheet specifically for property tax reporting, supported by actual tax bills.
- Related Organization Information: This documentation requires expanded disclosures for business relationships with commonly owned or affiliated entities.
- Capitalization vs. Expense Elections: SLFs and LTCFs must make sure that certain costs are consistently either capitalized or expensed. Additionally, facilities electing depreciation must apply depreciation through the asset schedules.
Navigating the 2025 cost reporting cycle
With the significant changes required for this upcoming cost reporting cycle, facilities face an even more complex process than last year. Before you begin reporting, review how the changes affect your facility to save time and ensure compliance with the new rules.
This material has been prepared for informational purposes only, and is not intended to provide or be relied upon for legal or tax advice. If you have any specific legal or tax questions regarding this content or related issues, please consult with your professional legal or tax advisor.
