Facilities Testimony

Testimony: Applications for Determination of Need from Long-Term Care Facilities

Testimony to the Massachusetts Department of Public Health Determination of Need Program relative to its Memorandum on Applications for Determination of Need from Long Term Care Facilities dated October 6, 2020.  This response is being presented on behalf of the members of Dignity Alliance Massachusetts.

Download the written testimony: DignityAllianceDPHDON.docx.

The Need for Skilled Nursing Facilities

Given the tragic loss of so many residents of long-term care facilities in Massachusetts far above the national average there is, in our opinion, NO need for any additional beds to serve the traditional general population of older adults or people with disabilities.  Even prior to the pandemic, the census in nursing homes was on the decline.  Additionally, Mass Senior Care, the nursing home industry trade organization, testified to the Legislature on April 19, 2019 that “lack of stable financing would result in 35 homes projected to be at risk of closure this year (2019), on the heels of 20 homes that shut their doors in recent months”.

We believe that the closing and consolidation of skilled nursing facilities and the lower bed census resulting from the tragic loss of residents to COVID-19, will produce a savings to the Commonwealth that should be re-invested in home and community-based supports and services, including affordable housing vouchers.  Older adults and people with disabilities deserve the dignity and respect of remaining in their home or their community and have demonstrated a clear preference for maintaining as much independence and choice as their health condition permits. Dignity Alliance strongly supports such a reimagining of long-term care.

In fact, there needs to be an independent assessment of all current nursing home residents, to determine their suitability for living in the community with adequate supports and services in keeping with Governor Baker’s Executive Order 576 advancing the concept of an “age-friendly Commonwealth.” This independent assessment should occur prior to granting any new or amended licenses to serve any of the specialized populations mentioned in the Memorandum of October 6, 2020.

We recognize, however, that while there is no demand for traditional congregate nursing facilities for most frail older adults, there may be current and future need for certain specialized facilities such as those envisioned in the Memorandum.  We propose that the conditions for permitting such facilities need to be strengthened to provide the best possible service to residents with the special needs that the Department has outlined and avoid the expense of unnecessary capacity.