Kiel Zillmer, Aaron Sagedahl Weigh In on OIG Report’s Impact on Nursing Home Policy in Law360 Article

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Kiel Zillmer, a partner in the Quarles & Brady Health & Life Sciences Practice Group, and Aaron Sagedahl, an associate in the group, were quoted in a Law360 article about a report from the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) on the effectiveness of an enforcement program aimed at underperforming nursing homes.

The report concluded that the program, aimed at strengthening poor-performing nursing homes, focuses too much on financial penalties rather than requiring meaningful changes that would positively impact the way the nursing homes operate, such as better staff training and needed facility repairs.

Zillmer and Sagedahl explained that while this isn’t an easy puzzle to solve, the report likely will spur movement in the right direction. An excerpt:

Turning around poor-performing nursing homes won't be as simple as making a few policy and enforcement changes. Attorneys at Quarles & Brady LLP said the watchdog report ignores many of the real-world challenges facing nursing homes, especially in rural areas where there's a shortage of qualified staff.

"There are simply no easy solutions when it comes to improving and maintaining the quality of care in long-term care facilities," partner Kiel Zillmer and associate Aaron Sagedahl said in a joint statement.

Zillmer and Sagedahl said it's reasonable to expect the report "will only further reinforce" CMS's efforts to impose nonfinancial enforcement measures.

"Nursing homes, particularly those with a history of noncompliance, should anticipate a greater emphasis on long-term compliance and corrective action rather than one-time financial penalties," the Quarles & Brady attorneys said.

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Originally published by Law360, November 4, 2025 (Subscription required.)

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