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Nov. 2, 2023

Minimum Staffing Comment Letters Posted

Two new additions have been added to our CMS Staffing Standard webpage: LeadingAge Minnesota’s draft comments, which will be filed by the end of the week, and LeadingAge’s final comments, filed earlier this week.

Log into your account to read our draft comment letter and LeadingAge’s submitted letter.

Minimum staffing resource site

Within our CMS Staffing Standard page on our webpage, we have posted our comment letter draft. Last night, LeadingAge made their submitted comment letter available to members. We have included a copy on the same resource page for your review.

As a reminder, you have until Monday, Nov. 6 at 10:59 p.m. CT to submit your comments on the proposed rule. You may wish to submit your comments ahead of the deadline in case there is a rush by others to do so.

Still time to submit your comments

There is still time to submit your comment letter. Within our CMS Staffing Standard page on our website, there is a sample comment letter template for you to utilize to let CMS know how the proposed minimum staffing rule standards would impact your situation. Also located on the site are various supporting documents to make submitting your comments easy. They include:

  • A how-to guide for filing comments
  • Facility-level fiscal analysis showing how much will be needed for compliance
  • Facility-level HPRD hardship exemption eligibility analysis
  • Compilation of issues analyses from Advantage over the past several weeks
  • A recorded Coaching Room event walking through the comment submission process

People who support and oppose the rule will submit comments, so sharing information about how the rule impacts your organization is critical. Older adults and their families deserve quality nursing home care: be sure CMS hears your thoughts!

Please reach out to Mark Schulz with any questions.

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