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One fallout of the COVID-19 pandemic is that some, already struggling skilled nursing facilities may now be becoming financially unviable. As a result, owners and operators of such facilities may be actively seeking to transfer facility operations to a separate entity as an alternative to closure. But when a Georgia hospital authority, for whatever reason, is transferring the operations of a facility that participates in the Medicaid upper-payment limit program, the transfer needs to be structured to comply with applicable program requirements, as well as Georgia hospital-authority law.