The article below is a top story from this week's ACTION newsletter—Care Providers of Minnesota's weekly newsletter for members. The newsletter focuses on current legislative issues, regulations, long-term care trends, and other Association news. Each Thursday evening, it is delivered to your inbox. To sign up for ACTION, contact Lisa Foss Olson (952-851-2483). To learn more about membership, visit our Become a Member page.

We need your comments on Medicare SNF proposed rule

Patti Cullen
By Patti Cullen, CAE  |  April 29, 2022  |  Skilled nursing facilities

Comments from nursing facility members on the implications of the SNF Medicare proposed rule will be absolutely critical this year—and, similar to the comment-writing campaign a few years ago on the requirements of participation, the profession will need thousands of comment submissions, not just a few hundred. Short, directed, and implications to your community are the best sorts of comments and the American Health Care Association/National Center for Assisted Living (AHCA/NCAL) has several resources to help you.  

The comment deadline is June 10, 2022. Details on what to ask and a form to submit your comments can be found at this AHCA/NCAL resource page (using this platform for comments is preferable). You can also submit comments directly to CMS. Please send a copy of comments sent to AHCA at:

Proposed outline for your comments:

  • Describe yourself and your operation 
  • Explain your commitment to quality—if you are a three-star or better building, any quality efforts underway 
  • Discuss how difficult the past two years were—sacrifices made, tragedy of losses, and maybe a specific team member example 
  • Explain the impact of a 4.6% reduction on your residents: phased in reduction would give time for census recovery, loss in census and increased labor costs 
  • Discuss your workforce challenges: open positions, difficulty in filling shifts, use of agency staff, nobody to recruit, etc.

Other suggestions:
  • Describe yourself and your operations: What you do and how long you have been in this line of work 
  • Why you work in long-term care 
  • Location of your building and description of your building (number of rooms/units)
  • Profile of your residents 
  • Discuss how you and your team feel about your residents

AHCA has done a few webinars on review of the rule and tips on commenting—recordings are available:

To access the recordings
  • Go to the link and log in using your username and password
  • Once the page opens, click on the “View Archived Recording" button on the right hand side of the page—the presentation will open in a new window for you to view and hear the program
  • Click on the “Handout“ tab to download your copy of the handouts and other available materials 

Patti Cullen, CAE  |  President/CEO  |  |  952-851-2487



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Care Providers of Minnesota is a non-profit membership association with the mission to Empower Members to Performance Excellence. Our 900+ members across Minnesota represent non-profit and for-profit organizations providing services along the full spectrum of post-acute care and long-term services and support. We are the state affiliate for the American Health Care Association/National Center for Assisted Living, and with our national partners we provide solutions for quality care.

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