Comment from LeadingAge

Summary: LeadingAge, an organization representing nonprofit aging services providers, opposes the proposed rule because it uses aggregate wage data that fails to distinguish between high-paying acute care hospitals and lower-paying long-term care facilities. They argue that the proposed wage floors will be unattainable for many long-term care providers due to fixed Medicaid and Medicare reimbursement rates, potentially pricing them out of the EB-3 visa pathway and reducing available care for older adults.