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In a February 10 letter, National Citizens' Coalition for Nursing Home Reform Executive Director Elma L. Holder, backed by about 60 organizations, urged U.S. Health and Human Services (HHS) Secretary Otis R. Bowen to adjust regulatory proposals to the Omnibus Budgetary Reconciliation Act (OBRA, P.L. 100-203, Subtitle C, Nursing Home Reform) and incorporate public expertise into their development.
Last fall, the Health Care Financing Administration (HCFA) published two sets of regulations aimed at implementing most of the recommendations of the Institute of Medicine's (loM) report, "Improving the Quality of Care in Nursing Homes." The first set, published October 16 in the Federal Register, aimed to reformulate conditions of participation per loM (see this column, January/February '88). The second, published November 18, dealt with survey, certification, and enforcement.
According to a November 18 preamble, the HCFA sought principally to accomplish the following:
1. Establish a flexible survey cycle for SNFs, ICFs, and ICFs/MR in the Medicare and Medicaid programs to ensure the element of surprise during inspections,
2 . Provide that for Medicare, survey agency findings of continued compliance constitute a recommendation that is subject to review by the HCFA;
3. Provide that for Medicare, survey agency findings of continued compliance constitute a recommendation that is subject to review by the HCFA;
4. Strengthen the requirements affecting participation of facilities with repeat deficiencies;