TAKE ACTION NOW....Submit Comments on the Requirements of Participation Proposed Rule to CMS by Wednesday, October 14!!

If you haven't already, please submit comments on the Requirements of Participation Proposed Rule to CMS by COB Wednesday, October 14th!!

Act Now

On July 16, 2015, the Center for Medicare and Medicaid Services (CMS) published the proposed rule titled Medicare and Medicaid Programs: Reform of Requirements for Long-Term Care Facilities: Proposed Rule in the Federal Register.

CMS extended the comment period for the Requirements of Participation proposed rule to October 14th. The more than 5,000 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. You are having an impact! We must ensure that CMS continues to hear us - we can't stop now.

It is CRITICAL that member nursing centers continue to submit additional comments this week and drive home the message that this proposed rule will put access to care at risk and take scarce dollars away from caregiving.

PHCA/CALM will also be commenting on our members' behalf, but your comments are essential to help us maximize the impact on CMS.

How to Submit Comments

PHCA developed a sample letter that outlines the most concerning issues. Members can use this sample letter as a basis for their comment letter.

Submitting a letter is easy, and your comments do not need to be very long. A meaningful paragraph about how the proposed rule will affect the nursing center and the residents served will have a significant impact. Comments can be submitted electronically or by regular mail.

To submit electronically go to the CMS website.

If you would prefer to submit your comment via regular mail, send it to:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-3260-P
P.O. Box 8010
Baltimore, MD 21244

AHCA's webpage is a good resource for members. The page contains suggested comment topics, sample comments, instructions for filing a comment and a link to the filing site. To access the AHCA webpage CLICK HERE.

A few guidelines to keep in mind as you prepare your comment letter:

  • Be sure to keep the focus on the beneficiaries - your residents - rather than on your business or operational results. That will get CMS to pay attention!
  • The more personalized you can make your comment, the better. Use your own circumstances and your own examples to drive home your message.
  • Submit comments on behalf of yourself rather than your company or other third party. (Please do not submit your comments on behalf of PHCA.)
  • The comment deadline is COB October 14, 2015.

If you have any questions or need assistance please contact Gail Weidman, Director of Policy & Regulatory Affairs at gweidman@phca.org or Dawn Murr-Davidson, Director of Quality Initiatives at dmurrdavidson@phca.org.


To better inform members of the provisions contained in the proposed rule PHCA hosted a webinar earlier this month titled "CMS Proposed SNF Regulations to Cost $726 Million in Year One, $47,000 Per Facility: What You Can Do Now!". The webinar was presented by Paula G. Sanders, Esq. with Post & Schell, PC. The webinar has been recorded and can be found on PHCA's website. The power point presentation for the webinar can also be found on the PHCA website.

Thank you for your support! Together, we can make a difference for quality care.