As the Centers for Medicare and Medicare Services (CMS) implements updates to the Guiding an Improved Dementia Experience (GUIDE) Model, assisted living (AL) providers may receive requests from GUIDE Participants to enter into new or updated partnership agreements. These agreements are intended to comply with new CMS requirements that took effect July 1, 2026.
For many AL providers, these partnership requests represent a new CMS requirement rather than a change initiated by the GUIDE Participant. The updated agreements are intended to ensure continued participation in the GUIDE Model under the revised residential care community (RCC) requirements.
The GUIDE Model is an eight-year, voluntary Medicare model that began in July 2025 to improve care coordination and quality of life for people living with dementia and their caregivers. GUIDE Participants (Medicare Part B-enrolled providers and suppliers selected by CMS) may partner with RCCs, including AL to deliver certain GUIDE services through a written partnership agreement.
Effective July 1, 2026, CMS established a new regulatory framework for RCC participation in the GUIDE model. GUIDE Participants that currently partner with AL communities, or wish to do so in the future, must obtain CMS approval before adding an RCC as a partner, execute CMS compliant partnership agreements, and submit additional information about Partner Organizations. As part of this process, AL providers may be asked to provide information regarding ownership and controlling interests, related organizations, governance, and organizational information to satisfy CMS reporting and oversight requirements.
CMS also implemented several important operational changes. Residents of dedicated memory care communities or units are no longer eligible to participate in GUIDE. In addition, GUIDE respite services are no longer available for residents of AL communities, regardless of whether they have a primary caregiver. CMS also established a separate RCC payment category for GUIDE Participants.
AL providers currently participating in GUIDE, or considering participation, should carefully review any proposed partnership agreements, understand the disclosure requirements, prepare to provide the required organizational information, and evaluate how these policy changes may affect residents and operations.
Please contact AHCA’s Population Health Policy Analyst
Rohini Achal or
Nisha Hammel, Vice President, Reimbursement Policy & Population Health with any questions.