Commissioner Monica Bharel, MD, MPH s1

December 12, 2016

Commissioner Monica Bharel, MD, MPH Massachusetts Department of Public Health 250 Washington Street Boston, MA 02108

Dear Commissioner Bharel:

I am writing to express my strong concern regarding the Department’s proposed rescission of 105 CMR 151.000, General Standards of Construction for Long-Term Care Facilities in Massachusetts and the incorporation of certain sections into 105 CMR 151.000, Licensing of Long Term Care Facilities. Specifically, I respectfully urge you to maintain the current grandfathering of nursing facilities built on or prior to March 19, 1968 and reject the proposed amendment. Nursing facilities provide a core state service to individuals who can no longer live safely in the community. We are proud of the care we provide and are committed to providing high quality services to frail elders and individuals with disabilities.

Riverbend cares deeply for our father. Elimination of the 1968 grandfathering provision would have dire consequences for our father who has been a resident at the facility for nearly half a decade. At 92 years old, our father who suffers from PTSD due to issues suffered as a decorated combat medic in WWII is fragile. Riverbend has been very caring and accommodating as not to move our dad around even within the same facility out of concern for his mental health. Moving our dad to another facility even for the best of intentions would be a shock amounting to life- ending change in continuity. While we appreciate the changes and agree that the conditions of facilities needs to be improved, we feel that grandfathered provisions are necessary to provide the continuity of care our older seniors need. Ripping them out of their existing environment would be a very bad outcome for most all of the residents who are in their twilight years.

Again, I respectfully and strongly urge you to reconsider this proposed regulatory change and would welcome the opportunity to meet with you to discuss the impact this regulation would have on residents, and their families. Thank you for your consideration. Please do not hesitate to contact me. .

Sincerely,

Dennis Fitanides (father Peter Fitanides at Riverbend in Natick) 54 Stagecoach Drive Ashland, MA 01721 [email protected] 617-694-8331