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A Guide to Submitting Comments on CMS's Proposed Nursing Home Staffing Standards; Webinar Materials Available
On September 6, 2023, the Centers for Medicare & Medicaid Services (CMS) released the long-awaited Notice of Proposed Rulemaking (NPRM) that proposed a minimum staffing standard in nursing homes. While Consumer Voice supports a minimum staffing standard, the proposed staffing standard does not go far enough to protect nursing home residents. The NPRM is now in the 60-day comment period, and comments are due on November 6, 2023. It will be critical that CMS hears from you that this rule needs to be stronger.
Materials are available from last week's webinar, A Guide to Submitting Comments on CMS's Proposed Nursing Home Staffing Standards. This webinar provided guidance on how to comment on critical provisions of the NPRM, including:
- The need for a stronger minimum staffing standard.
- Reducing the timeframes for implementation of the rule.
- CMS’s proposal to allow certain nursing homes exemptions from the standard.
- Support for the 24/7 RN requirement.
- Facility assessments.
- Medicaid Transparency.
In the webinar, Consumer Voice also provided step-by-step instructions on how to submit your comments to CMS. To submit simple comments and use Consumer Voice's suggested talking points, follow these instructions.
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Template Comment Letter for Organizations
Consumer Voice has worked with other consumer groups and unions, including Justice in Aging, the Center for Medicare Advocacy, the AFL-CIO, the Service Employees International Union, the National Committee to Preserve Social Security and Medicare, California Advocates for Nursing Home Reform, Michigan Elder Justice, the Long-Term Care Community Coalition and others, to develop a template letter for advocates to use to suggest improvements in CMS's proposed nursing home staffing rule and to show support for finalizing it. We know that the nursing home industry is pouring millions of dollars into an effort to derail the NPRM. We need to counter that! The template may be adapted to reflect your organization’s priorities and/or the experience of your members/constituents. Feel free to circulate this template among member and partner organizations.
Download the template language and add your organizational or personal perspective. Visit our website for specific instructions on how to submit this letter. Comments are due by November 6, 2023.
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New Podcast Episode: Residents Amplify Their Voices for Change
 Listen to the new episode of the Pursuing Quality Long-Term Care podcast, Residents Amplify Their Voices for Change. For decades Consumer Voice has designated October as Residents’ Rights Month. This month is an opportunity to recognize the value of each resident and the importance of treating every resident with dignity and respect. This year’s theme, Amplify Our Voices, highlights residents coming together to make their voices heard.
In this episode, join us as we speak with two resident advocates. Floyd Hartley is a former nursing home resident who now lives in the community and works as an advocate for all residents including those transitioning out of facilities. We also spoke with Cindy Napolitan, a current nursing home resident who has lived in two different nursing homes for over six years and has advocated for herself and others at the local, state, and federal level during that time.
Floyd and Cindy discuss how they work to improve conditions for nursing home residents. Their constant effort and advocacy illustrate how residents can use their own voices to make systematic change for consumers in long-term care facilities.
Listen to the podcast on Spotify, Apple Podcasts, SoundCloud, Facebook, Youtube, or our website.
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Participate Virtually in the Consumer Voice Conference
 There's still time to register to watch the livestreaming and recordings of the Consumer Voice Conference next week! Session highlights include:
Diversity, Equity, Inclusion, and Accessibility: What Does it Mean for Long-Term Care, Advocacy, and You?
Join us to learn about diversity, equity, inclusion, and accessibility (DEIA) as it applies to your programs and advocacy. Subject matter experts will discuss disparities in health care; define and highlight the need for working towards diversity, equity, inclusion, and accessibility; and describe structural racism and how to address it in daily advocacy and long-term services and supports policy change. Hear how two Long-Term Care Ombudsman Programs are incorporating DEIA in their program’s policies, practices, and advocacy. Consumer Voice leadership will share our initial DEIA work, goals, next steps, and how members can be involved. Attendees will have ample time for robust discussion with the panelists.
No Country for Old People – Advocacy Through Film
In No Country for Old People, a documentary, a filmmaker chronicles the last 6 months of her mother's life in a five-star nursing home and discovers the system designed to protect our most vulnerable is actually a complex and opaque system that puts profit over people. Through interviews with dozens of experts, No Country for Old People shows how health care decisions are governed by financial considerations to the detriment of nursing home residents. In this session, we explore the power of storytelling to advocate for change in the face of a powerful lobby seeking to maintain the status quo. No Country for Old People is a new way to advocate – it is a film that uses storytelling to educate the public about the long-term care business model that puts profit over people, shows the consequences on residents, and activates the public to demand change. It is a tool that engages and energizes the public, asks legislators, policy-makers, and enforcement agencies to prioritize quality long-term care, and counteracts a nursing home industry that lobbies for the status quo. Educating and motivating through storytelling is a powerful and effective way to shift the collective consciousness and empower the public to demand that the system be changed to provide quality long-term care.
Federal Partner Updates on Activities to Promote and Achieve Quality Long-Term Care and Services
There are a number of efforts underway at the federal level to improve conditions in long-term care facilities, protect residents, and improve access to long-term care, services, and supports. Join our partners from the Centers for Medicare and Medicaid Services, Administration for Community Living, and Department of Justice as they provide overviews of the various initiatives impacting individuals needing and accessing long-term care.
- Panel 1: Jonathan Blum, Office of the Administrator, Centers for Medicare & Medicaid Services, Principal Deputy Administrator & Chief Operating Officer; Edwin Walker, Administration on Aging/Administration for Community Living, Deputy Assistant Secretary for Aging
- Panel 2: Evan Shulman, Centers for Medicare & Medicaid Services, Director, Division of Nursing Homes; Susan Lynch, U.S. Department of Justice, Senior Counsel for Elder Justice
Resident Empowerment Luncheon & Plenary - Fire Through Dry Grass
Fire Through Dry Grass, an OPEN DOORS/Reality Poets documentary film, uncovers the real-time devastation experienced by residents of a New York City nursing home during the coronavirus pandemic. Using GoPros clamped to their wheelchairs, Andres “Jay” Molina and fellow Reality Poets, Vincent Pierce and Peter Yearwood, all residents of Coler Nursing Home, on Roosevelt Island, New York, document their harrowing experiences on “lock down.” Join a discussion with Jay, Vince, Pete, and their colleagues, Jennilie Brewster, Alex Eshelman, and Mikko Cook as they share their experiences during COVID, the making of this award-winning documentary, and the resulting movement to improve conditions in nursing homes.
See the agenda for the many more can't-miss sessions.
Register Now. Virtual attendees can watch the livestream of all plenaries and most breakouts, plus have access to session recordings for 90 days.
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