On July 13, 2015, CMS issued a much-anticipated proposed rule seeking to consolidate the long-term care (LTC) facility participation requirements for the Medicare and Medicaid programs. This major proposal marks the first comprehensive changes to the LTC conditions of participation since 1991. As noted by CMS, the revisions are designed to align with current clinical practice standards in an effort to improve the safety, quality, and effectiveness of care delivered to facility residents. Strikingly, CMS estimates in its regulatory impact statement that the total projected cost of this rule would be almost $730 million in the first year and more than $638 million annually thereafter. Comments regarding the proposed rule are due to CMS by September 14, 2015. * CMS subsequently extended the comment period until October 17.  For more information on the proposed rule, see our Client Alert.