Tuesday, August 18, 2015

Comment Period on Requirements of Participation Extended to Oct. 14

Blair Jackson 

CMS has extended the comment period for the proposed rule on Requirements of Participation to October 14. The thousands of comments that have been submitted so far are helping CMS realize this is a very important issue that has a significant effect on our profession. We are making a difference, but we can't stop now. We need to continue to tell CMS that the proposed rule goes too far, demands the changes too quickly, and costs too much. If you haven't already, please submit a comment prior to the October 14 deadline using the dedicated webpage AHCA has created.

The webpage includes suggested topics for commenting, instructions for filing a comment, and a link to the filing site. The webpage has recently been refreshed with new content, including a video from AHCA/NCAL President and CEO Mark Parkinson discussing the Association's efforts. In addition, there are new sample comment letters on the webpage. There also is a link to a side-by-side comparison of the proposed and current regulations. The webpage can be accessed here or directly from the AHCA website by clicking on the "SNF Requirements of Participation" link under the "Facility Resources" tab.

AHCA encourages anyone with an interest in the well-being of our nation's frail and elderly to join the growing number of people who are submitting comments to CMS regarding the proposed rule on Requirements of Participation.

The Association provides the following guidelines for submitting a comment:

· Your comment does not need to be very long. A meaningful paragraph about how the proposed rule will affect you, your patients and your residents will have significant impact.

· The more personalized you can make your comment, the better. Use your own circumstances and your own examples to drive home your message.

· 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 will get CMS to pay attention.

· Submit your comment on behalf of yourself rather than your company or other third party. Please do not submit your comment on behalf of AHCA or your state association.

· You can submit your comment electronically or by regular mail. The AHCA website provides the link for electronic submission and the address for regular mail.

 · Log your comment by clicking the link on the dedicated AHCA webpage so that AHCA can keep track of how many comments have been submitted.

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