General panel comments

That stark fact, along with evidence that employment in the long-term care sector has not yet recovered to levels seen before the public health emergency (2020),1 requires a ramp-up time to meet the new requirements, and for some facilities even that timeline may not be sufficient to keep the facility open. [...] Increasing the staffing pool and ensuring the appropriate type of personnel in rural communities will be challenging, given the finite pool of personnel available implied by the data provided by CMS (FR 61377). [...] Third, we suggest that CMS consider implementing, to the extent possible within statutory jurisdiction, other recommendations of the Committee on the Quality of Care in Nursing Homes, National Academies of Sciences, in their Consensus Study Report in 2022. [...] Within the staffing realm, Goal 2 of that report is to “ensure a well-prepared, empowered, and appropriately compensated workforce,” and the Panel concurs with the associated set of recommendations. [...] Responses to requests for comments on specific elements of the proposed rule Rural Definition (FR 61381) The panel recommends using the same definition of rural used in determining eligibility to participate in the Medicare Rural Hospital Flexibility Program as a designated Critical Access Hospital (22 CFR 45.610(b)(5).