MedicaidAdministrativeMedium impact
Cost Report Update – New Attestation on Hold Harmless Arrangements
Illinois Medicaid - HFS·IL · Geriatrics·Provider Notice
Effective date
Aug 14, 2026
We identified it
Aug 15, 2026
Summary
Illinois requires Long Term Care facilities to attest on their 2026 cost report that they do not participate in hold harmless arrangements for health care-related taxes, where the state or government provides direct/indirect payment, offset, or waiver guaranteeing tax relief. This is a compliance attestation requirement under federal Medicaid rules (42 CFR § 433.68(f)(3)) and prohibits arrangements involving redistribution of Medicaid payments among providers.
Action Required
By August 14, 2026 (immediate): This policy applies to Long Term Care facilities (nursing facilities, ICF/IID, and MC/DD facilities) in Illinois only. Billing and compliance teams at affected LTC facilities must: (1) Ensure authorized facility officers review and understand the new attestation language on Page 1 Section II of the 2026 cost report; (2) Confirm the facility does not participate in any hold harmless arrangements involving Medicaid payment redistribution among providers; (3) Complete and sign the new attestation statement on the cost report; (4) Contact the Bureau of Long-Term Care at 844-528-8444 toll-free if there are questions or if the facility participates in any provider payment redistribution arrangements. Failure to properly attest or disclosure of unreported hold harmless arrangements could result in cost report rejection, audit findings, and potential loss of Medicaid provider status.