Good morning, ProviderNation. The fine folks at CMS have asked for your thoughts on their proposal for a sweeping set of “competence-based” rules for long term and post-acute care, and, by jove, you’ve given them something to think about.
As of this writing, more than 1,500 commenters have flooded CMS’ zone. Most appear to run to the negative, and most appear to focus on the additional burdens the rules might create, as well as the pace of changes they’ll entail. Typical is an unsigned letter writer from North Carolina, who says “these rules focus on process and prescriptive procedure … rather than fairness.”
“Documentation, although important,” your North Carolinian goes on to say, “seems to be a focus rather than obvious outcomes reflective of the care given. The proposed rules add more to the complex web of new paperwork requirements; do little to promote the quality of care while adding substantial costs to regulatory compliance.”
Paul Mathenge, a registered nurse and care manager at Puyallup Nursing & Rehabilitation Center in Puyallap, Wash., says he’s “incredibly concerned” about the proposed changes. “I can understand that the intention and principles behind the changes are good, though the amount of staff time required to run these programs is cumbersome,” Mathenge says, adding that some kind of five- to six-year glide path might make the proposed rules more realistic.
“If we want the system to be successful we must have a solid strategic plan and realistic goals,” Mathenge adds, “resident care and positive outcomes should be our first focus.”
An unsigned letter from Georgia points out that his/her center was recently docked a star by CMS because too many of the center’s residents were on antipsychotic medications. “The nursing home was safely implementing a program to reduce its residents’ [use of] such medications, but could not do it more quickly … because many such medications require the patients’ doses to be slowly reduced,” the Georgian says. “Consequently, to avoid the punitive effects of the regulations … the nursing home would have had to endanger the patient.”
More Regulation, Not Less, Needed
Of course, not all of the negative comments are against the proposed rules. A Californian writes in to say that the proposed rules don’t go far enough to regulate long term and post-acute care centers. That correspondent urges CMS: to require a registered nurse to assess a resident’s condition before sending the resident on to emergency rooms; to require any center that charges for Internet access to “ensure bandwidth necessary to facilitate a resident’s reasonable use of online, streaming entertainment;” and to “scrutinize the” relationship between skilled nursing centers and medical directors “more closely.”
“Currently,” the Californian says, “the rules allow medical directors to assume multiple medical-directorship positions, at several SNF/NFs. The rules do not require the SNF/NF or medical director to demonstrate whether the additional duties would be/are feasible… If one medical director holds a medical-directorship position at another facility, then please impose a duty on each SNF/NF to explain how that medical director achieves, annually, the contractual and patient-specific obligations necessary to attain the highest quality outcomes possible.”
Len Russ Is Ready For His Closeup
CMS will take comments thru Sept. 14. The fine folks at AHCA/NCAL want you to know that they’re happy to help providers have their voices heard thru the association’s own website.
But don’t listen to me. Take it from our favorite current AHCA board chair.