Position Papers

LTC and Consumer Advocacy

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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