AMDA Submits Comments on CMS Reforms of Regulations for Long Term Care Facilities
This week AMDA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Rule Reform of Requirements for Long-Term Care Facilities. AMDA’s extensive comments showed an overall support of the intention of the updates, provided recommendations, and shared concerns regarding some of the proposals.
AMDA concurs with CMS that quality care should be focused on the resident of the nursing home and that while quality has improved over the past two decades, there are additional improvements needed. “We support the proposal to combine quality of care and quality of life requirements, based on the rationale that these are intertwined and are relevant to all residents/patients regardless of the length of their stay or reasons for their admission.”
AMDA also agrees that more comprehensive training for staff and practitioners will benefit patient care but notes that it is concerned “about inadequate staff and practitioner training and skills specific to the nursing home population. Some health care professionals providing care in nursing homes have limited knowledge of general or geriatric medicine and relevant regulatory requirements. We agree that merely being a licensed health care practitioner does not ensure competence to provide high-quality nursing home care.” AMDA further noted that the ,“proposed requirements related to competencies appear to focus extensively on a relative handful of topics (for example, behavior, pain, depression, dementia, trauma, cultural competence) with little or no mention of many equally important issues that affect the correct approaches to these complex and challenging post-acute and long-term care residents/patients.“ Among its various recommendations, AMDA noted that “CMS focus much more on how to strengthen the basic skills and knowledge that can help improve the management of a broad spectrum of residents/patients with their diverse conditions and risks—not just on facts and techniques related to a few specific conditions.”
AMDA also noted that it “strongly recommends that nursing facilities have a means to evaluate the competencies of their medical directors, attending physicians, and other medical practitioners.” Given the proposed regulations require other providers within nursing facilities, such as dieticians, to carry a national certification, AMDA recommended that CMS “acknowledge the need for adequate medical director knowledge and training, and acknowledge the need for and availability of core competencies for attending physicians.”
AMDA also noted overall concerns “about the very different approach [CMS has] taken with this massive overhaul of all of the regulations.” AMDA suggested that prior to finalizing any of these proposals, CMS have a more open process and an opportunity for an “open and joint discussion” with adequate time to address the many issues the proposed regulations address. Considering the breadth and importance of the proposed revisions for – that are being proposed for the first time since originally finalized in 1991, AMDA urged CMS to address stakeholder concerns and have more dialogue moving forward.
To read AMDA’s full comment letter, click here.