Dignity Alliance urges the Department to set the bar high and suggests that all the listed priorities are important. Applicants should be required to state what they will do to support each of the priorities listed in the Memorandum and any others required by the Department.
Issue
Issue: Rather than require an applicant to address at least one of the DON Health Priorities, we recommend that an applicant be required to address how they are addressing priorities a through f, in addition to any other long-term care priorities. In addition to requiring that the applicant be in compliance with applicable federal and state laws and regulations, we believe that this review of compliance apply to the three years preceding the application for the specialized DON provided in the Memorandum dated October 6, 2020.
(Note: DON is Determination of Need)