Volume XXX, Number 9
 September 2015

Your Immediate Action is Needed
Take Action Now!

Comments needed on CMS Proposed Rule on Requirements of Participation

Over the last week, AHCA has launched a massive grassroots campaign to send thousands of comment letters to CMS and AHCA created a dedicated webpage to help you directly and easily submit comments to CMS. THCA is working with AHCA on this campaign to impress upon CMS just how important this is to Texas nursing facility residents and to our profession. We are not just asking for your company to submit comments. We will need every administrator, every director of nursing, every corporate officer, every support staffer, everyone with a vested interest in the future of this profession – including you – to submit separate comments. We will need thousands of them to make an impact. This appears to be the only way we can demonstrate to CMS how burdensome this new regulation is.

The webpage has been refreshed with new content, including a new video from AHCA/NCAL President & CEO Mark Parkinson discussing our efforts. In addition, there are new sample comment letters on the webpage, even Mark’s own personal letter to CMS expressing his concerns about the rule’s impact on centers and beneficiaries. There also is a link to a side-by-side comparison of the proposed and current regulations.

This webpage makes it easy for anyone to participate in the campaign. You can find suggested topics, sample comments, instructions for filing a comment, and a link to the filing site. You can access this information here or directly from the AHCA website by clicking on the “SNF Requirements of Participation” link under the “Facility Resources” tab.

Collectively, these provisions are a time and cost nightmare. CMS itself projects that the cost of implementing the provisions is $726 million in year one. That equates to a cost of $47,000 for every facility in the country. After closely examining the potential impact of the individual provisions, AHCA believes that CMS has understated the costs, and the actual burden may be as high as twice the original forecast.

What you can do
We need you and as many individuals in your organization as possible to submit individual comments to CMS on its proposed changes to the SNF/NF Requirements of Participation. We will need thousands of them to make an impact. This appears to be the only way we can demonstrate to CMS how burdensome this new regulation is.

We are asking that you and others in your organization send a meaningful paragraph about how the proposed rule will affect you and your patients. You can easily submit your comment electronically or by regular mail.

A few guidelines to keep in mind

  • As you are preparing your comment, be sure to keep the focus on the beneficiaries — your patients and residents — rather than on your business or operational results. That’s the best way to 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. In other words, tell your story.
  • Submit your comments on behalf of yourself rather than your company or other third party. Specifically, please do not submit your comments on behalf of THCA or AHCA. We will be preparing our own extensive comments and providing them to CMS.
  • After you have filed your comment, please let AHCA know by clicking here or on the link provided on the webpage. That way AHCA can keep track of how many comments have been submitted. This will also allow AHCA to recognize you with a special ribbon badge at AHCA’s annual convention in San Antonio this October.
  • Be sure to submit your comment prior to the September 14, 2015 deadline.

Your participation will have a profound impact on the final CMS rule. Collectively, we can make a real difference.


Kevin Warren

President’s Report


 Legislative Update


 Commitment to Care

If you have any questions about the THCA C to C Initiative or would like to share your facilities successes please contact me at gbwilliams@txhca.org or call (512) 458-1257.


State News


National News

  • Your Immediate Action is Needed – Take Action Now!
    Comments needed on CMS Proposed Rule on Requirements of Participation


Announcements & Recognitions

THCA’s 65th Annual
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AHCA/NCAL 66th Annual
Convention & Expo
October 4-7, 2015
San Antonio, Texas

Our Great State of Texas is the host state for the AHCA/NCAL Annual Convention & Expo, October 4-7, 2015! Experience the National Conference right here in our home state!

Pre-Registration Rate available until September 9, 2015

Onsite Registration Rate available September 10, 2015 -October 7, 2015

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