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SouthWest Society of Service Coordinators "Serving the needs of professionals in the field of developmental disabilities"
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The following article is a "Must Read" for all providers of ICF/MR services. It will remain on this web site until the rules are published. Please take the time to read it and write a letter. Pass the information on to others in the field. How to Become a Higher Priority By Jan Hannah I recently had the opportunity to talk with a Centers for Medicare and Medicaid Services (CMS) surveyor of Intermediate Care Facilities for people with Mental Retardation (ICFs/MR) otherwise and affectionately know as a “fed” or a “federal surveyor”. Just getting to talk to someone who gets the blame for all the bad things that happen to ICFs/MR was a rare treat. But, she was able to give me a piece of information or maybe advice in which everyone operating under the ICF/MR regulations will be interested. During the conversation, she mentioned that the new regulations were ready for publication but were a low priority so no push was occurring to get them in the Federal Register and out for public comment. As you know, that is the first step in the process of getting new regulations approved. ICFs/MR are still operating under the regulations that became effective in 1988 (which means they were really written in the early to mid ‘80’s). There has been only one change since that time. However, that change involved the way surveys are conducted, i.e. a new protocol was developed rather than the regulations actually be changed or rewritten. That change resulted in certain tag numbers being looked at more closely while others are not looked at at all. The provider is still held accountable for complying with the entire set of regulations, however, and the surveyor can look for compliance with all regulations if, in the surveyor’s opinion, there is a problem and closer scrutiny is required. Therefore, the over all net affect was for some regulations to be emphasized and others de-emphasized. But, bottom line, there has not been a change in the ICF/MR regulations since 1988. Now, to the present. It appears that CMS, like our state and federal legislators, responds to gentle but persuasive pressure. As a result, if we all begin to write letters urging the publication of the new regulations AND send copies of our correspondence to our US Congressman and Senators, (maybe even the President?) that just maybe we can convince CMS to publish the new regulations. We were told they are ready for publication, but they are at the bottom of the priority list. That they are just sitting, waiting to become someone’s priority. So, let’s start writing and see if we can get them on someone’s radar screen! If you want to write, here are some things you might use as talking points:
As As always, your own stories and experiences will give your letter that personal appeal that can convince the powers-that-be that our issues deserve to be heard; that we deserve to be moved from the bottom of the pile. Here is who to write to:
Linda Joyce |