Today, 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 to not take a “one-size fits all” approach and take recommendations from its own study that clearly showed that no specific number is the solution. Instead, this critical problem requires a multi-faceted approach including taking into account 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 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 healthcare system.
Milta Little, DO, CMD
AMDA – The Society for Post-Acute and Long-Term Care Medicine