Advocacy Correspondence and Comments

ADVOCACY CORRESPONDENCE & COMMENTS

COMMENTS & STATEMENTS

  • October 23, 2023

Comments to CMS on Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting

Lutheran Services in America submitted comments urging CMS not to institute a mandate for minimum staffing requirements with no additional funding support, which will exacerbate the current workforce crisis and make it even more difficult for providers to hire the staff needed to provide care.

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  • October 5, 2023

Response to House Committee on Ways & Means RFI on Improving Access to Health Care in Rural and Underserved Areas

Lutheran Services in America submitted a response to a recent Request for Information announced by the House Committee on Ways & Means, seeking stakeholder input on factors driving health care facility closures and workforce shortages and harming overall access to care, especially in rural and other underserved areas.

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  • September 11, 2023

Comments to CMS on Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies, etc.

Lutheran Services in America submitted comments to the Centers for Medicare and Medicaid Services supporting the proposed creation of new Medicare billing codes for community health integration and social determinants of health (SDOH) risk assessments, as well as connections to services and supports, and encouraging the agency to consider further expansion of this work in the future.

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  • August 14, 2023

Comments to ACL on Older Americans Act

Lutheran Services in America submitted comments on the update to the regulations governing the Older Americans Act.

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  • June 29, 2023

Comments to CMS on its Proposed Rule Related to Medicaid Access

Lutheran Services in America submitted comments urging CMS to support regular rate reviews and competitive wages for direct service providers (DSPs) within the current payment model, not to mandate that..

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  • June 3, 2022

Comments to CMS on its Request For Information on Establishing Mandatory Minimum Staffing Requirements at SNFs

Lutheran Services in America submitted comments urging CMS to reconsider establishing mandatory minimum staffing requirements at SNFs in order to protect access to care for older adults.

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Letters

  • October 25, 2023

Letter to Department of Labor and Office of Management and Budget Urging Alignment on Overtime Rules and Nonprofit Federal Grant Payment Amounts

Lutheran Services in America joined with other nonprofit groups to ask OMB to insert language in the final rule they are drafting governing nonprofit federal grants to ensure award amounts..

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  • October 17, 2023

Letter to Secretary of State Antony Blinken Urging the Correction of Visa Retrogression Issue for International Nurses to Benefit LTC Workforce

Lutheran Services in America joined with other organizations working in skilled nursing and longterm care to ask the State Department to end the freeze on EB-3 visas and bring the..

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  • March 17, 2023

Letter to Chair Bernie Sanders and Ranking Member Bill Cassidy, Senate Health, Education, Labor, and Pensions (HELP) Committee

Lutheran Services in America responded to the Committee’s request for Information on the drivers of health care workforce shortages and ideas for potential solutions.

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  • March 14, 2023

Letter to House and Senate Appropriations Leaders urging them to support greater funding for affordable senior housing

Lutheran Services in America joined other national organizations to urge Congress to support robust funding to meet the affordable housing needs of older adults in Fiscal Year 2024.

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  • March 6, 2023

Letter to Ur M. Jaddou, Director, U.S. Citizenship and Immigration Services about Fee Schedule and Changes to Certain Other Immigration Benefit Request Requirements

Lutheran Services in America joined other partners to send USCIS a letter urging them to consider operational methods to save costs rather than increasing costs for the same level of..

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  • March 22, 2022

Letter to President Biden commending his support for home and community-based services in the State of the Union Address.

Lutheran Services in America-Disability Network joined a coalition of disability and aging organizations to thank President Biden for highlighting the need to expand home and community-based services in the State..

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  • March 17, 2022

Letter to Secretary of Health and Human Services Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure

Lutheran Services in America-Disability Network joined a coalition of disability and aging organizations to urge the Administration to provide at least 120 days advance notice when it intends to lift..

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  • March 3, 2022

Letters to Centers for Medicare and Medicaid Services Administrator on the Agency's New SNF Initiative

Letters to Centers for Medicare and Medicaid Services Administrator on the Agency’s New SNF Initiative Lutheran Services in America CEO Charlotte Haberaecker sent a letter to Administrator Chiquita Brooks-LaSure.  In..

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  • January 22, 2022

Letter to White House staff requesting assistance with anticompetitive practices in direct care staffing agencies

Lutheran Services in America joined with other national nonprofits to urge the White House to help address direct care temporary staffing agencies charging supercompetitive prices during the public health emergency.

  • August 17, 2021

Letter to Secretary of State Antony Blinken regarding Immigrant Visa Prioritization

Lutheran Services in America joined with other national nonprofits to ask State Department to amend the Immigrant Visa Prioritization update and prioritize the entry of foreign-trained nurses and health care workers..

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Endorsed Letters & Legislation

  • September 28, 2023

House of Representatives Bipartisan Letter to HHS Secy. Becerra Raising Concerns about SNF Minimum Staffing Rule

Lutheran Services in America endorsed a letter sent by a bipartisan group of Representatives raising significant concerns about CMS’s proposed rule mandating minimum staffing levels and 24/7 RN coverage at..

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  • September 26, 2023

The Housing Alignment and Coordination of Critical and Effective Supportive Health Services (ACCESS) Act

Senator Edward J. Markey (D-MA) and Senator Alex Padilla (D-CA) introduced the Housing Alignment and Coordination of Critical and Effective Supportive Health Services (ACCESS) Act. The legislation would align housing and services for people experiencing chronic homelessness and unnecessary institutionalization. In sum, the bill aims to make Medicaid services work better with housing.

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  • August 22, 2023

The Homeless Children and Youth Act (HCYA)

The legislation aligns federal definitions of homelessness for children and youth, streamlining assistance, leveraging resources, and bringing greater visibility to the reality of family and youth homelessness.

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  • July 28, 2023

Improving Access to Medicare Coverage Act of 2023

This legislation will make days spent in observation count towards Medicare’s three-day inpatient stay requirement for Skilled Nursing Facility (SNF) coverage.

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  • May 3, 2023

Volunteer Driver Tax Appreciation Act

The legislation raises the volunteer mileage rate to the standard business mileage rate for volunteers who drive their vehicles on behalf of charitable nonprofits to transport property or individuals.

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  • April 18, 2023

Family Stability and Opportunity Vouchers Act

The bill creates 250K housing vouchers, paired with mobility-related services (counseling, case management), targeted to families with young children to help them move to neighborhoods with good-performing schools, childcare, or..

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ADVOCACY CORRESPONDENCE & COMMENTS

Communications with Members

March 16, 2022

Join Us to Urge CMS to Reconsider SNF Initiative, Including Minimum Staffing Requirements

Join us to send a message to your lawmakers and CMS Administrator Chiquita Brooks-LaSure: we are very concerned that the proposals regarding minimum staffing requirements and punitive enforcement for skilled nursing facilities (SNFs) will exacerbate the current workforce crisis nonprofit long-term care providers face and lead to additional nursing home closures and fewer older Americans being able to access the care they need. 

February 7, 2022

Act Now to Help Your Employees Access the Public Service Loan Forgiveness Program

The federal government recently created two new opportunities for nonprofit employees to request full forgiveness of their direct federal student loans.  The time investment for nonprofit employers to support people in these requests is minimal and can be a powerful tool to show support for qualifying employees.

LETTERS

March 3, 2022

Letters to Centers for Medicare and Medicaid Services Administrator on the Agency's New SNF Initiative

Lutheran Services in America CEO Charlotte Haberaecker sent a letter to Administrator Chiquita Brooks-LaSure.  In it, she expressed our concerns that the proposals regarding minimum staffing requirements and punitive enforcement for SNFs will exacerbate the current crisis our members face and lead to additional nursing home closures and fewer older Americans being able to access the care they need, and asking that as CMS embarks on this work that the views and experiences of our network be included in the research study being planned in the coming year that will inform the proposed rules around minimum staffing.

January 22, 2022

Letter to White House staff requesting assistance with anticompetitive practices in direct care staffing agencies

Lutheran Services in America joined with other national nonprofits to urge the White House to help address direct care temporary staffing agencies charging supercompetitive prices during the public health emergency.

COMMENTS & STATEMENTS

June 17, 2021

Statement from Lutheran Services in America Affirming Support for Equitable Access to High-Quality, Affordable Health Care

Following the decision by the Supreme Court to dismiss a challenge to the Affordable Care Act, Lutheran Services in America released the following statement from Charlotte Haberaecker.

November 11, 2020

Statement from Lutheran Services in America Urging Support for Equitable Access to High-Quality, Affordable Health Care

Urging Congress and the Administration to safeguard in federal law protections for underserved populations throughout America.