Pioneer Network Call to Action

SUBMIT COMMENTS BY AUGUST 11 FOR CMS PROPOSED RULE IMPACTING CULTURE CHANGE

The Centers for Medicare & Medicaid Services (CMS) is seeking comments by Wednesday, August 11, for a proposed rule related to the use of civil money penalty funds for nursing homes, which has important implications for the culture change movement.

Supported by a grant from the Rothschild Foundation, the Pioneer Network has created an electronic toolkit – including model language that you can simply cut, paste, and send – with all of the necessary information to submit comments in just a few minutes.

Pioneer Network strongly encourages all organizations and coalitions supportive of culture change to submit comments following the set of instructions below.

It's an easy, yet critical, policy action you can take to advance the culture change movement.

INSTRUCTIONS TO SUBMIT COMMENTS ELECTRONICALLY:

1. Copy and paste the model comments into a new document. The document title may vary, we suggest including your organization name and the rule reference number. 
   (Ex: PioneerNetworkCMS2435P)
   
   
2. Include a paragraph describing your organization in the indicated area in the model comments (second paragraph)
   
   
3. Include your organization name and contact information at the end of the comments (indicated)
   
   
4. If possible (but not necessary), include on your letterhead with an electronic signature
   
   
5. Submit your comments to CMS through the link provided below (complete all required information on the submission page and attach your comments as a PDF or Word file using the function on the page)

View Model Comments

Download Model Comments (Word doc)

Submit Your Comments Electronically

Review the Full Proposed Rule

Instructions on how to submit comments via regular or over night mail are included in the proposed rule. Given the short timeframe, Pioneer Network strongly encourages comments be submitted electronically to ensure that they are received prior to the August 11 deadline.

QUESTIONS?
If you have questions relating to submitting your comments, please contact Mina Addo at (301) 280-5714 or maddo@burnesscommunications.com.

BACKGROUND:
CMS is currently seeking comments by Wednesday, August 11, to a proposed rule (42 CFR Part 488) related to civil money penalty funds for nursing homes under the Medicare and Medicaid programs.

Pioneer Network applauds both Congress and the Administration's focus on promoting improvements in the health, safety and overall well-being of nursing home residents, and has urged CMS to prioritize culture change transformation in long term care settings as a successful quality improvement tool.

The proposed rule presents a concrete opportunity to embed culture change principles within the current system. To that end, Pioneer Network recommends three changes to the proposed rule that would further incentivize government and providers to focus more attention and energy to meaningful culture change:

1. Increase the amount of the federal portion of civil money penalty funds that are directed to CMS from 50 percent, in the proposed rule, to 90 percent;
   
   
2. Promote the federal funding of grant projects in culture change in nursing homes as a successful strategy for improving the health, safety and well-being of nursing home residents, leading to overall improvements in nursing home quality; and
   
   
3. Issue specific guidance requiring culture change to be incorporated into any quality improvement activities supported by civil money penalty funds.

In the Affordable Care Act and in other places, Congress and the Administration have signaled strong support of culture change in long term care. For example, Section 6114 of the Affordable Care Act includes a pilot project to develop best practices for nursing homes that are involved in the culture change movement. In order advance important quality improvement initiatives we must ensure that funding streams are available. Section 6114 includes language concerning development of funding streams for culture change. Civil money penalty funds seem to be ideal for fulfilling this portion of the legislative mandate. Directing additional funds to CMS and promoting evidence-based culture change initiatives is consistent with Congress and the Administration's position, and will help to transform long term care and spur real improvements in quality and outcomes for residents.