ADvancing States has submitted comments in response to the Long-Term Care Ombudsman Program Proposed Extensions with Changes of a Currently Approved Collection. ADvancing States is supportive of the intentions and goals ACL has articulated regarding the NORS changes. However, ADvancing States believes that the current timeline put forth by ACL is unreasonable and does not fully account for the systematic changes states will need to make to update their systems. The Federal Register notice states that the proposed modifications to NORS would be effective for FFY 2019-2021, which would establish an implementation date of October 1, 2018. We further note, given that October 1, 2018, is only seven months away, states would experience significant challenges in bringing their systems up to date.
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