Gov. Mark Parkinson sent out the following message earlier this week… Our Board of Governors has just approved a major grassroots initiative in which we will ask our members to submit individual comments to CMS regarding the proposed rule on Requirements of Participation.
The purpose of this campaign is to impress upon CMS just how important this is to our profession. What CMS has developed simply goes too far and demands the changes too quickly. We had hoped the agency would use this rule to modernize regulations, reduce the punitive nature of the survey process, and align regulations with person-centered care and the goals of our nationwide Quality Initiative. Unfortunately, there are far too many provisions in this 400+ page rule that double down on Washington micromanaging even basic functions in our centers.
Collectively, these provisions are a time and cost nightmare. CMS itself projects that the cost of implementing the provisions is $726 million in year one. That equates to a cost of $47,000 for every facility in the country. After closely examining the potential impact of the individual provisions, we believe that CMS has understated the costs, and the actual burden may be as high as twice the original forecast.
In order for this plan to be effective, we will need you and as many individuals in your organization as possible to submit comments to CMS on its proposed changes to the SNF/NF Requirements of Participation.
This message is a heads up so that you can begin to evaluate and gather your resources. We are not just asking for your company to submit comments. We will need every administrator, every director of nursing, every corporate officer, every support staffer, everyone with a vested interest in the future of this profession – including you – to submit separate comments. 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.
We want to do everything we can to make it easy for you to participate in this campaign. We are working on suggested talking points and guidance on how to submit comments (who to send them to and how). We will have more details and resources to share in the next few days.
In the past, our typical approach to a CMS proposed rule has been to seek member input and then file one large response from AHCA. That will not work here. In this instance, more is better. CMS must hear from us en masse. If we don’t generate thousands of responses, we can’t expect much change in the final rule. Those who want to ban arbitration agreements, who want minimum staffing requirements, and who want an even worse regulatory environment will respond with hundreds – and perhaps thousands – of comments. We must show CMS how important this is to us. We have seen the success of these efforts in other sectors. If done right, we can make an impact and influence the final rule CMS issues.
We have formed a team here at AHCA to oversee this critical initiative. Rae Anne Davis and Matt Smyth will oversee the effort. We have also assigned the staff person of each constituent group to work with those members who have questions. They are:
It’s often easy to throw up our hands in frustration and think Washington will never pay attention to what one constituency has to say. But I’m here to tell you that you CAN make a difference. Your participation – as small as it may seem – will have a profound impact on the final CMS rule.
Collectively, we can make CMS pay attention to the concerns we have. We can be a force for change. Together we can win.
More to follow shortly.