LeadingAge has submitted comments to CMS on a proposed rule that would reduce certain requirements in the rules on emergency preparedness that nursing homes and other in-patient providers must follow.

After careful review to understand the implications for emergency management and the possible impact on residents, staff and leadership, LeadingAge informed CMS that we supported two of the proposed changes and did not support two.

Policy makers have acknowledged in recent years a desire to reduce unnecessary hospitalizations and Medicare costs and deliver value-based services.  One area they could examine is the requirement that a beneficiary must have a three day inpatient hospital stay in order to be eligible to have Medicare pay for Part A skilled nursing facility care and services, and that the beneficiary must be treated in the hospital for a condition requiring SNF services post-release. This three-day inpatient hospital stay requirement can be waived when the Medicare beneficiary is an enrollee in Medicare Adv

LeadingAge’s comments focused on the following areas:

  • Grievance process
  • Quality Assurance and Performance Improvement (QAPI)
  • Discharge Notices
  • Abuse Reporting
  • Electronic Health Records
  • Facility Assessment
  • Infection Prevention and Control
  • Cumulative effect of the RoPs on staffing and ability to provide quality care

Additionally, LeadingAge addressed several payment and quality provisions of the Proposed Rule, including the following:


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