Public Comment of Alison Hirschel, Michigan Advocacy Project and

Michigan Campaign for Quality Care, in support of the Proposed Modifications to

The Nursing Home and Hospital Long Term Care Unit Bed Standards

June 21, 2006

      The Michigan Advocacy Project and the Michigan Campaign for Quality Care

wish to express support for the proposed changes to the Nursing Home and Long Term

Care Unit Beds Standards which are being presented today. We want to thank

Commissioner Brad Cory and Michigan Department of Community Health Deputy

Director Jan Christensen for their significant and thoughtful efforts to revise the

standards and their willingness to invite a wide range of stakeholders to provide in-put as

the modifications were being drafted. 

      We support the modifications for the following reasons:

1. We have long believed that certificates of need should only be issued to applicants who have demonstrated their ability to provide quality care. These modifications are a significant step forward in that important direction and consistent with previous efforts by this Commission to promote quality in the Facility Innovative Design program.

2. The modifications are consistent with the goals and recommendations of the Governor’s Medicaid Long Term Care Task Force which endorsed a variety of efforts to promote quality across the long term care spectrum.

3. The modified standards reward high quality and serve as an important incentive for providers to maintain quality over a period of time.

4. The standards also ensure that providers who have troubled homes or enforcement challenges focus on addressing those issues before taking responsibility for additional beds. 

5. The modifications are consistent with other efforts to promote quality including standards developed by the Department to determine when facilities may obtain additional Medicaid certified beds and thus create a more consistent focus on quality across various Departmental programs and systems.

We thank you again for your consideration of these proposed modifications and urge the

Commission to vote in support of these important changes.