A leading nursing home advocate is mustering support to combat massive changes the administration has proposed for Medicare and Medicaid participation.

“Volume really matters,” Cheryl Phillips, M.D., senior vice president for Public Policy and Advocacy for LeadingAge, tells readers in an open letter that urges operators to issue their own comments on the 403 pages of changes.

Phillips said LeadingAge itself will present the Centers for Medicare & Medicaid Services with a long list of concerns before the Sept. 14 deadline for comment submissions. Worries about staffing challenges and a plea to phase in new requirements over fives years will figure prominently in those comments.

The massive bundle of changes was unveiled the first day of the White House Conference on Aging and published in the Federal Register three days later on July 16. It is being called by some the biggest substantive changes to program participation rules in nearly 25 years. Among other things, it calls for quality assurance and performance improvement requirements; extensive infection control, compliance and ethics mandates; facility-wide assessment rules for determining staffing needs; and substantial changes to clinical practice regulations.

“We support the person-centered intent of some of these new proposed rules [but] many of these requirements are vaguely defined and subject to surveyor interpretation or assume new staff competencies that are also not well defined,” Phillips wrote.

She also claims the agency may be unduly changing good-faith clinical practice goals and “elevating” them to requirements that are unachievable for many facilities. She also calls some staffing proposals for rural providers “impossible.”

Comments may be submitted to CMS electronically or by hard-copy, but they must be received by 5 p.m. Eastern Time on Sept. 14.