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PHI Comments on Proposed Regulations for Long-Term Care Facilities

October 1, 2015

PHI submitted comments September 23 on regulations proposed by the Centers for Medicare and Medicaid Services (CMS) revising the requirements for long-term care facilities to participate in Medicare and Medicaid programs.

This was the first comprehensive review and update of federal regulations (pdf) governing long-term care facilities conducted by CMS since 1991. The proposed changes address a wide range of subject matters, including staffing, training, nutrition, abuse, care planning, and more.

PHI’s comments largely focus on providing residents with quality, person-centered supports and services through a well-trained, adequately sized direct-care workforce. PHI’s coaching and consulting work with facility staff around the country, as well as its research, policy advocacy, and workforce curriculum development, offer a valuable, 360-degree perspective on effective nursing home care and workforce issues

PHI’s recommendations include, among many:

  • CMS should use payroll-auditable staffing data and resident case mix to develop mandatory staffing ratios.
  • Staff training requirements should be expanded and pre-employment training hours should be increased to 120 hours to accommodate additional training content.
  • Coordination and communication between residents, facility staff, and family should be facilitated to the furthest extent possible.

PHI’s full comments are available at the PHI National Clearinghouse on the Direct Care Workforce.

— by Stephen Campbell, PHI Policy Research Associate

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