Monday, August 8
Proposed Rules for Skilled Nursing and Intermediate Care Facilities
Please see the NASW Illinois Chapter comments on the Proposed Rules for Skilled Nursing and Intermediate Care Facilities.
Susan Meister, Division of Legal Services
Illinois Department of Public Health
525 W. Jefferson St 5th Floor
Springfield, Illinois 62761
RE: PROPOSED RULES FOR SKILLED NURSING AND INTERMEDIATE CARE FACILITIES
Dear Ms. Meister:
The National Association of Social Workers, Illinois Chapter, represents 7,000 social workers in Illinois. In 2003, NASW published standards for Social Work Standards in Long-Term Care Facilities. The guiding principles focus on the “preservation and enhancement of a person’s physical and social functioning, the promotion of the conditions essential to ensure maximum benefits from long-term health care services, the prevention of physical and mental illness and increased disability, and the promotion and maintenance of physical and mental health and an optimal quality of life.”
NASW Illinois is a strong supporter of the Nursing Home Reform efforts and the resulting legislation. We believe that the Nursing Home Reform legislation represents a significant leap forward toward assuring the quality of care and service that residents of nursing homes in Illinois need and that they and their families should expect. However, it is in the rules that this legislation will be interpreted, and we believe that these rules must reflect the intent on the legislation in order to give the department, residents, families and advocates the tools to “[E]nsure maximum benefits from long term health care services.”
Therefore we are writing in support of the recommendations put forth by the Illinois AARP and the Illinois Citizens for Better Care (ICBC), both of which set out specific ways to strengthen the direct care components of the proposed rules. Citing the Abt Associates study—the most comprehensive study of direct care minimum staffing requirements to date—both organizations refer to the need to specify direct care service in hours, not percentages. As noted in the ICBC comments, “[I]t is inexcusable to adopt the registered nurse requirement from the Abt study without also adopting the entire licensed nurse requirement from which it was derived.” They also make recommendations to make waivers to the rules more transparent to the interested public. We understand that rules provide minimum standard and that some individual providers will seek to provide the minimum. Thus the comments made in the AARP document to strengthen the notion of what the department expects are critical.
Finally, ICBC mentions the percentage of direct care time imputed to the Director of Nursing and Social Services Director. Direct service by a social worker is an important component of direct care and there is some evidence that nursing homes with better qualified social service staff have fewer psychosocial deficiencies. For starters, we advise the department to specify the number of hours of direct service required by the Social Service Director.
Thank you for the opportunity to comment on the proposed rules for skilled nursing and intermediate care facilities.
Very truly yours,
Phyllis Mitzen, MSW, ACSW Joel L. Rubin, MSW, CAE
Chair, NASW Illinois Chapter Executive Director, NASW Illinois Chapter
Older Adults Shared Interest Group