September 4, 2023
On Friday, September 1, the U.S. Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), issued a proposed rule that seeks to establish comprehensive staffing requirements for nursing homes—including for the first time, national minimum nurse staffing standards.
AMDA – The Society for Post-Acute and Long-Term Care Medicine, while applauding the effort by CMS to support staffing in nursing homes, is concerned about a “one-size-fits-all” approach of mandating a specific minimum number for all nursing facilities to meet. As stated in AMDA’s Position on Staffing Standards in Long Term Care (08-10-2022), the Society recognizes that while having adequate staffing is critically important, minimum staffing levels should not become a fixed ceiling. Staffing levels based only on resident-to-worker ratios or assumptions that staff availability is an easily fixable variable will not adequately or safely address and meet residents' needs.
CMS’ request for “alternative approaches” and the possibility of providing flexibility in implementing this rule is encouraging. The Society strongly urges CMS not to take a “one-size-fits-all” approach and take recommendations from its own study that clearly showed no specific number is the solution. Instead, this critical problem requires a multi-faceted approach, including taking into account the complexity of the population (e.g., facility case-mix), availability of nurses, training programs, as well as innovative models that incorporate telehealth and technology advances to improve efficiencies and access to expertise, and the workplace culture.
The Society has long urged CMS and the federal government to invest in the post-acute and long-term care workforce to improve the quality of life and quality of care for our nation’s nursing home residents. A trained and committed workforce that works in a supportive environment is the backbone of our nation’s health-care system.
###
About AMDA – The Society for Post-Acute and Long-Term Care Medicine
AMDA – The Society for Post-Acute and Long-Term Care Medicine is the only medical specialty society representing the community of over 50,000 medical directors, physicians, nurse practitioners, physician assistants, and other practitioners working in the various post-acute and long-term care (PALTC) settings. Dedicated to defining and improving quality, we advance our mission through timely professional development, evidence-based clinical guidance, and tireless advocacy on behalf of members, patients, families, and staff. Visit www.paltc.org for more information.
