As has been reported several times in Care Connectionand Friday Update, CMS issued a proposed rule change for the SNF Medicare and Medicaid Requirements for Participation on Monday, July 13, 2015.

WHCA/WiCAL is working with American Health Care Association to impress upon CMS just how important this is to our profession. What CMS has developed simply goes too far, demands the changes too quickly, and costs too much. There are too many provisions in this 400+ page rule that result in Washington micromanaging even basic functions in your centers.

American Health Care Association has developed a dedicated web page to help you submit comments before the September 14 deadline to CMS regarding the Proposed Rule on Requirements of Participation. The page is accessible via the home page of, by clicking HERE, or via the AHCA/NCAL website.

What You Can Do

WHCA/WiCAL needs as many individuals in your organization as possible to submit individual comments to CMS on its proposed changes to the SNF/NF Requirements of Participation. We will need thousands of them to make an impact. This appears to be the only way we can demonstrate to CMS how burdensome this new regulation is.

The new web page will make it easy for you to participate in this campaign. It includes suggested topics for commenting, sample comments, instructions for filing a comment, and a link to the filing site.

Filing comments is not as daunting as it may sound. A thoughtful letter will be very helpful. Your comment doesn’t even have to be that long. A meaningful paragraph about how the proposed rule will affect you and your patients and residents will have significant impact. And you can easily submit your comment electronically or by regular mail. We have seen the success of these efforts in other sectors. If done right, we can influence the final rule that CMS issues.

A Few Guidelines to Keep in Mind

As you are preparing your comment, be sure to keep the focus on the beneficiaries — your patients and residents — rather than on your business or operational results. That’s the best way to get CMS to pay attention.

The more personalized you can make your comment, the better. Use your own circumstances and your own examples to drive home your message. In other words, tell your story.

Submit your comments on behalf of yourself rather than your company or other third party.Specifically, please do not submit your comments on behalf of WHCA/WiCAL or AHCA. We will be preparing our own extensive comments and providing them to CMS.

After you have filed your comment, please let AHCA, and in turn WHCA/WiCAL, know by clicking HERE and fill out the very brief survey. This will help us keep track of how many comments have been submitted and allow AHCA to recognize you with a special ribbon badge at AHCA’s annual convention in San Antonio this October.

ALSO… AHCA facilities that provide 10 letters or more will be entered into a drawing to win an iPad at AHCA/NCAL’s Fall Convention in San Antonio on Oct. 5-6.

Be sure to submit your comment prior to the September 14, 2015 deadline.

Your participation will have a profound impact on the final CMS rule. Collectively, we can make a real difference. If you have questions about filing a comment, please send let AHCA at

Posted in Regulatory