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Methodology · Ownership Graph

Ownership Graph — How We Trace Operator Chains

CMS publishes the direct owner of every Medicare-certified nursing home, but the operator’s ultimate parent — the private equity fund, REIT, or holding company that actually controls portfolio decisions — is rarely just one layer up. This is how we go further, and what we will and will not assert.

Why the direct-owner layer is not enough

The CMS All Owners dataset (sourced from PECOS provider enrollment) lists any party with a 5%+ direct or indirect ownership interest. In practice, most filings stop at the immediate operating entity — typically a single-purpose LLC named after the building. Two facilities that look unrelated by direct owner can in fact be sibling investments of the same private equity fund or the same real-estate roll-up. Without the higher layers, cross-portfolio bad-actor analysis is impossible.

Sources, by layer

1. Direct owner — CMS PECOS All Owners

The party that signs the Medicare provider agreement, typically a state-formed LLC or corporation with the same address as the facility. Refreshed when CMS publishes a new snapshot of the All Owners dataset (roughly quarterly).

2. Immediate parent — state Secretary-of-State filings

For each direct-owner LLC, we look up the registered agent and member filings in the state of formation. Where the state publishes member or manager names, we can resolve the next layer up — typically a holding company or operating partner. Not all states publish this; coverage varies by state law.

3. Ultimate parent — SEC filings, manual verification

Public REITs and PE funds with public-facing investor disclosures can be tied back to the operating partner via 10-K, 10-Q, and S-1 filings. Privately-held PE funds are traced through industry reporting, academic datasets (e.g. Steiner et al.’s long-term-care PE database), and direct disclosure. Each ultimate-parent assertion carries a source URL and a verification date.

Refresh cadence

  • Direct layer (PECOS): re-ingested when CMS publishes a new All Owners snapshot, currently quarterly.
  • Immediate parent: verified the first time we surface an operator and re-checked annually thereafter (or when an article triggers a re-look).
  • Ultimate parent: verified manually; the row carries a last_verified_at timestamp visible to anyone with API access.

Known limitations

  • Not every chain has been traced past the direct layer. Operator pages display “Ultimate parent: not yet verified” rather than guessing.
  • Some states do not publish LLC member filings. Coverage of the immediate-parent layer is best in DE, FL, NY, CA, PA, TX and weakest in WY, NM, NV.
  • PE funds that hold via cascading single-purpose LLCs can require 4–6 layers of state filings to resolve. We currently model up to 10 layers but verify only as many as the public record supports.
  • Ownership at a moment in time. CMS PECOS captures the current direct owner, but transactions can lag the dataset by months. Do not treat the chain as a real-time disclosure.
  • The chain marks individuals, government, and standalone non-profits as terminal nodes — these are correctly one layer deep, not gaps.

How Placet displays it

Operator profiles include a chain visualization with one column per verified layer, from direct owner on the left to ultimate parent on the right. Each node carries a type label (Individual, LLC, Corp, REIT, PE fund, Public Co, Government, Non-profit) and the source we used. Where we have not yet verified the layer above the direct owner, the page shows “Ultimate parent: not yet verified” with a link back to this page rather than asserting a parent we cannot defend.

FAQ

What does an ownership chain show?

An ownership chain walks from the direct owner of a facility (the entity CMS lists in the All Owners dataset) up through any parent companies, holding LLCs, private equity funds, or REITs that ultimately control the operator. The deepest verified node is the ultimate parent.

Why does CMS only publish the direct owner?

The CMS All Owners dataset, derived from PECOS enrollment, requires nursing homes to disclose any party with a 5%+ direct or indirect ownership interest. In practice, providers commonly file the immediate operating entity (often a single-purpose LLC) and stop there. Tracing further up the chain requires cross-referencing state Secretary-of-State filings, SEC disclosures, and direct provider data.

What sources does Placet use?

Phase 1 (current): CMS PECOS All Owners for the direct layer. Phase 2 (in progress): state Secretary-of-State entity filings to resolve LLC parents. Phase 3 (planned): SEC filings for public REITs and PE funds, plus reporter and academic disclosures cross-referenced and manually verified.

How often is the data refreshed?

The CMS direct-owner layer refreshes whenever we re-ingest the federal pipeline (currently quarterly). Higher-layer data is verified manually as we add it; each row carries a last_verified_at timestamp.

What does "Ultimate parent: not yet verified" mean?

We have not yet traced this operator's chain past the direct owner shown in CMS. It does not mean the direct owner has no parent — only that we have not independently verified one and are not willing to assert it from secondary sources. We prefer "not yet verified" over guessing.

Are there cases where the chain is intentionally truncated?

Some operators are owned by individual people, by genuine standalone non-profits, or by government entities — in those cases the direct owner is the ultimate parent and the chain is correctly one level deep. The chain visualization marks these explicitly so a single-level chain is not confused with missing data.

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