Comment from American Health Care Association/National Center for Assisted Living (AHCA/NCAL)

Summary: The American Health Care Association/National Center for Assisted Living (AHCA/NCAL) supports the Department of Labor's goal of establishing a uniform joint employer standard but requests specific refinements to protect long-term care providers. They argue that routine regulatory compliance, patient-safety staffing directions, and standard vendor performance metrics should not trigger joint employer liability.