Y'all gotta read this. It's easy to understand, expands on the reasoning behind each portion of the proposed staffing rule, evaluates the deeper issues, and debunks the hyerbole.
Janice Hoffman-Simen and Michael Wasserman who are the present and past presidents of the California Association of Long-term Care Medicine, respectively, with an absurd number of pedigrees- wrote an in-depth evaluation that challenges the reader to think from the inside of the facility as well as put industry arguments in context.
I also find it interesting (not really, it's perfectly logical) that this report recommends a direct care expenditure ratio and ownership transparency, the samee thing Texas Caregivers for Compromise worked on in a bill in the 88th regular session in Texas with AARP Texas and the Texas Long-term Care Ombudsman Program. SB1629 was filed by Senator Lois Kolkhorst and made it through the Senate but fell victim to clock shenanigans on the final day that Senate bills could be heard on the House floor. New Jersey, New York, Massachusetts, and Pennsylvania have already put such bills in place so maybe by next session, we can catch up.
Do take the time to read these comments. It's long but that's because there are citations and references throughout. I hope CMS takes the time to thoroughly read through this as well. Read online here or download the response here.