Public Comment: 1k2-9176-k8w4

1/31/2018

https://www.fdms.gov/fdms/getcontent?objectId=0900006482e77ff9&format=xml&showorig=false

PUBLIC SUBMISSION

As of: 1/31/18 1:22 PM
Received: January 29, 2018
Status: Draft
Tracking No. 1k2-9176-k8w4
Comments Due: January 29, 2018
Submission Type: Web

Docket: CMS-2017-0167
PRA Notices (Misc. 2016-2017)
Comment On: CMS-2017-0167-0030
Agency Information Collection Activities; Proposals, Submissions, and Approvals
Document: CMS-2017-0167-DRAFT-0085
OK

Submitter Information
Name: Stan Ruffner
Address:
Oklahoma City, OK, 73105
Email: [email protected]

General Comment
The agency information collection has several flawed requirements
1) States were notified on 12/27/17 about the effective date of 1/1/18
2) Instructions subsequently sent as the Appendix was simplistic and did not provide enough detail
3) States were informed on 12/7/17 that a FAQ would be published for use - there is no FAQ as of 1/29/18
4) States are required to get approval from SPARC, Board and others prior to rate changes - data compiled
is compromised by the short notice
5) 10661 - indicates that the reporting period states that the data collection is for each Federal Fiscal Year
- beginning with Oct
6) CMS is requiring a reporting period of Jan 1, 2018 thru Dec 31, 2018 which is in conflict
7) The comment period would have been better to be implemented in early 2017 - it is ludicrous for the
comment period to be after the reporting period begins
8) Our estimated time to research is over 60 hours at this point - not sure where you came up with the
time estimate

https://www.fdms.gov/fdms/getcontent?objectId=0900006482e77ff9&format=xml&showorig=false

1/1