Position Papers

LTC and Consumer Advocacy

November 6, 2023 – NASOP signed on to a letter to CMS with its public comments on the recent Notice of Proposed Rulemaking that establishes a national minimum nursing home staffing standard.

October 30, 2023 – On September 6, 2023, the Biden Administration published a notice of proposed rulemaking (NPRM) that would, for the first time, establish a national minimum staffing standard for nursing homes participating in Medicare and Medicaid. There is now a 60-day comment period ending November 6th in which the public can weigh in on this proposed rule.

NASOP has added its support to this important issue. Click on Support Strong Minimum Staffing Standard in Nursing Homes  to read why a minimum staffing standard matters, and for instructions on how to add your organization’s name to the sign-on letter.

August 14, 2023 – Earlier this summer, when the Administration for Community Living (ACL) issued a notice of proposed rulemaking (NPRM) in order to update the implementing regulations of the Older Americans Act of 1965, NASOP submitted comments (NASOP – Comments on OAA Regulations 2023-08) that relate to experiences and challenges faced by LTC ombudsman programs and their designated entities and representatives in providing ombudsman services to residents of LTC facilities.

June 9, 2023 – NASOP added its support for this 6-9-23 letter to CMS regarding related-party transactions and audited Medicare cost reporting.

May 31, 2023 – NASOP signed on to a letter to the Senate and House Appropriations Committees from the Leadership Council of Aging Organizations (LCAO), encouraging them to pass FY 2024 appropriations without continuing resolutions.

May 31, 2023 – NASOP signed on a letter to President Biden to thank him for his support for family caregivers in the April 18, 2023 Executive Order, that will prioritize action to better recognize, assist, include, support, and engage our nation’s family caregivers.

February 2, 2023 – NASOP signed on a letter to CMS, expressing strong support for the agency’s efforts to address the staffing crisis in nursing homes across the country.

2022

December 6, 2022 – NASOP

November 28, 2022 – NASOP signed on this recent letter urging Congress to include important nursing home reform provisions in any omnibus bill passed during the lame duck session.

September 21, 2022 – The House Select Sub-Committee conducted a hearing on the impact of COVID-19 on nursing home residents and staff on 9/21/22. Mairead Painter, Connecticut State LTC Ombudsman, provided written testimony; see Letter for the record from CT SLTCO on the impact of Covid on SNFs 9-2022.

June 10, 2022NASOP – Response to CMS RFI on Staffing 6-10-22. NASOP submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to their Request for Information regarding the implementation of a minimum staffing standard in nursing homes.

May 26th, 2022Testimony of Mairead Painter CT LTCOP 2022 1. Mairead Painter (CT), NASOP First Vice President, will be testifying today before the House Appropriations Sub-Committee on Labor/HHS. She will be presenting the NASOP request for additional, stable funding under Title VII of the Older Americans Act.

March 15, 2022FAIR Support Letter. NASOP joined other organizations in a letter to Speaker Pelosi and Minority Leader McCarthy urging the House of Representatives to pass Forced Arbitration Injustice Repeal (FAIR) Act, H.R. 963, legislation which would make forced arbitration agreements between consumers and corporations illegal.

2021

December 8, 2021Inclusion_of_Nursing_Home_Provisions_in_Build_Back_Better_Act. NASOP joined other organizations in support of the inclusion of important protections for nursing home residents in the Senate’s version of the Build Back Better Act. The Build Back Better Act recently passed by the House includes provisions that, if passed, would make a significant difference in the lives of nursing home residents.

2020

August 24, 2020LCAO-Letter-Endorsing-Access-Act-Senate-Final. NASOP joined other organizations in support of the Advancing Connectivity during the Coronavirus to Ensure Support for Seniors Act (ACCESS Act, S. 3517)

Prior to 2019

August 4, 2017Letter to Seema Verma, CMS Administrator.  Revision of Requirements for Long Term Care Facilities regard Arbitration Agreements, CMS-3342-P, and RIN 0938-AT18

June 22, 2017Letter to Seema Verma, CMS Administrator. Burden reduction in the LTC Requirements and proposed changes to payments for therapy- 0938-AS96

June 16, 2016Letter to Andrew M. Slavitt, CMS Acting Administrator. CMS-1655-P, Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the LTC Hospital Prospective Payment System and Proposed Policy Changes, Fiscal Year 2017 Rates; Quality Reporting Requirements for Specific Providers; Graduate Medical Education; Hospital Notification Procedures Applicable to Beneficiaries Receiving Observation Services; and Technical Changes Relating to Costs to Organizations and Medicare Cost Reports.

January 4, 2016Letter to Andrew M. Slavitt, CMS Acting Administrator. Comments on 42 CFR Parts 482, 484, 485; Medicare and Medicaid Programs; Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals and Home Health Agencies; Proposed Rule

September 11, 2015Letter to Andrew Slavitt, CMS Acting Administrator. Comments on 42CFR PARTS 405,431,447, Et. Al., Medicare and Medicaid Programs; Reform of Requirements for LTC Facilities; Proposed Rule

February 3, 2014Letter to Lisa Parker, Director Division of Institutional Quality Standards at CMS.  Regarding: Proposed Rule CMS-3260-P “Reform of Requirements for Long-Term Care Facilities and QAPI Programs” and Comments on the absence of 42 CFR 483.10 CMS Nursing Home Access and Visitation and 483.12 marginalizes residents rights. Comments on 42 CFR 488.301 Substandard Quality of Care Definitions; and the Interpretive Guidance Appendix PP of the State Operations Manual.

October 1, 2013Letter to Sen. Bernard Sanders, Rep. Tom Harkin and Sen. Lamar Alexander Regarding Reauthorization of the Older Americans Act.

Medicaid

August 1, 2017Letter to Senator Ron Wyden, Insufficiency of Personal Needs Allowance for Medicaid LTC Residents

July 27, 2015Comments on Medicaid Managed Care Proposed Rule

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