Friendship Village Tempe Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Feb. 8 -- Gary D. Cook, treasurer of Friendship Village Tempe Board, Arizona, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicaid Program: Medicaid Fiscal Accountability Regulation". The comment was written on Feb. 1, 2020, and posted on Feb. 4, 2020:

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I am currently the Treasurer of the Board of Directors of Friendship Village Tempe, a continuing care retirement community. I have served in this capacity for two years.

As a member of the Board of Directors of the Community, we are charged with the fiduciary management of the Community and look out for the betterment of the lives of the 750+ residents who reside in our Community. Currently, our Community benefits from a waiver from the state nursing facility assessment as a continuing care retirement community.

The likely impact of this proposed rule is that the state Legislature would have no choice but to repeal the current exemption from the nursing home provider bed tax that currently applies to continuing care retirement communities.

In our Community, we would anticipate that impact to be approximately $480,000 per year. In a continuing care retirement community, the primary revenue source is the collection of fees charged to its Residents.

Each resident would likely face hundreds of dollars in new costs per year, as the nursing bed assessment would have to be passed on to residents.

CMS also claimed that MFAR would not have "a significant economic impact" on small businesses. Our Community qualifies as a small business and is significantly impacted as stated above. CMS should revise and reconsider its comments based on the impact to small businesses.

We respectfully ask CMS to modify the proposed rule and allow states to continue to have full authority to determine how they want to operate their own state nursing home provider bed tax program.

Sincerely,

Gary D. Cook

Treasurer of the Board of Directors

Friendship Village Tempe

2645 E. Southern Avenue

Tempe, AZ 85282

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2019-0169-0001

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