Mealey's (September 27, 2019, 9:53 AM EDT) -- NEW YORK — A federal judge in New York on Sept. 24 dismissed for lack of subject matter jurisdiction a complaint filed by 31 skilled nursing facilities seeking pre-enforcement review of a final rule promulgated by the Centers for Medicare and Medicaid Services (CMS) that permits investigative surveys of nursing facilities initiated in response to complaints to be conducted without the participation of a registered nurse (Avon Nursing and Rehabilitation, et al. v. Alex M. Azar II, No. 18-CV-2390, S.D. N.Y., 2019 U.S. Dist. LEXIS 163420)....