NACCHO Comments on CMS Proposed Rule for Long-Term Care Facilities

On July 16, the Centers for Medicare and Medicaid Services (CMS) invited the public to comment on a proposed rule reforming requirements for long-term care facilities participating in CMS programs. The proposed rule is intended to update requirements–which have not been comprehensively updated since 1991–to reflect industry advancements, improve the quality and safety of healthcare provided by federal programs, and reduce procedural burdens on providers.

The proposed changes address a variety of topics, including placing long-term care facility residents and their representatives at the center of care, shifting expectations to a competency-based approach to allow for flexibility in implementation of the requirements among facilities, and aligning standards with current health and safety knowledge. The rule places particular emphasis on antibiotics due to their widespread use in long-term care facilities given increasing national and international concern about antibiotic resistance. An estimated 40-75% of antibiotics prescribed in nursing homes may be unnecessary or inappropriate, making it a crucial topic to address in the proposed rule.

NACCHO, emphasizing the critical role of local health departments in preventing and controlling infections that emerge in community and healthcare settings like long-term care facilities, submitted a letter to CMS to provide comments and recommendations on how CMS can foster successful implementation of these reforms.

NACCHO supports the proposed rule’s focus on antibiotic resistance as it represents a growing threat to the health of the public and a significant challenge to the healthcare system. With the growing understanding that coordination between facilities will have greater impact on preventing antibiotic resistance than independent, individual facility efforts alone, it is important to recognize the need for and value of actively including and supporting local health departments and other stakeholders in antibiotic stewardship efforts. Local health departments play a leading role in the preparedness for, investigation of, and response to outbreaks, including those due to antibiotic-resistant organisms, making them crucial partners in efforts to address antibiotic resistance.

Another important consideration of the CMS proposed rule is the support needed to comply with and expedite implementation of the reforms. Long-term care facilities will need adequate funding, staffing, expertise, training, and support to develop protocols and monitoring systems for the use of antibiotics, improve infection prevention and control, and address other reforms in the proposed rule. Local health departments’ experience and expertise in addressing antibiotic resistance and promoting antibiotic stewardship makes them essential partners in these efforts.

NACCHO is committed to antibiotic stewardship and supporting local health departments’ work in addressing antibiotic resistance and promoting antibiotic stewardship. Learn more about the following:

About Sara Chang

Sara Chang is a senior program analyst for NACCHO’s Infectious Disease team. She works with local health departments on such topics as emerging infectious diseases, infectious disease prevention and control, and healthcare-associated infections. Twitter: @changsara

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