Over the last year, the Biden administration has been exploring the implementation of a federal minimum staffing mandate for skilled nursing facilities as part the Administration’s nursing home care initiative. CMS is expected to make an announcement by May 1st of a new minimum staffing mandate that may be as high as 4.1 hours per patient day (HPPD). While MSCA shares the Administration’s goal of increasing staff in nursing facilities in order to ensure the safety and well-being of our residents, we are extremely concerned that a 4.1 HPPD mandate during a historic workforce crisis would have a disastrous impact on access to quality nursing home care at a time when qualified caregivers are in short supply and state and federal reimbursement already underfunds the sector.
AHCA/NCAL has issued a call to action, requesting member facilities join a letter writing campaign informing key decision makers (e.g., CMS and the Administration) of concerns related to a potentially unfunded minimum staffing mandate. We urge all members to submit comments by February 28, 2023 following the instructions outlined by AHCA and found here.
Important points to consider in letters coming from Massachusetts nursing facilities include but are not limited to:
- Massachusetts already has a minimum HPPD requirement of 3.58, and a large number of facilities have been unable to achieve the current state standard given the lack of supply of licensed nurses and certified nursing assistants.
- 1 in 5 caregiving positions is vacant in Massachusetts nursing facilities despite significant efforts by facilities to hire qualified staff; and
- Even if the additional caregivers were available to hire, nursing homes do not have adequate funding to pay for this level of additional staff.
AHCA/NCAL recorded a free webinar providing an overview of the issue (requires registration/facility membership), and step by step guidance on crafting an effective letter to key decision makers.