Argentum joined with a coalition of industry stakeholders to submit comments in response to the proposed rule issued in September that would establish federal staffing requirements on long-term care facilities. The rule would apply only to Medicare and Medicaid-certified skilled nursing facilities (SNFs), and not residential senior living communities.
Under CMS’s proposal, nursing homes participating in Medicare and Medicaid would be required to provide residents with a minimum of 0.55 hours of care from a registered nurse per resident per day, and 2.45 hours of care from a nurse aide per resident per day. In addition, nursing homes would also be required to ensure a registered nurse is on site 24 hours per day, 7 days per week and to complete robust facility assessments on staffing needs. CMS would also impose new reporting requirements for states to report on the percentage of nursing home Medicaid payments that go to compensation for direct care workers and support staff.
Our comments specifically called attention to potential unintended impacts of the rule on settings that are otherwise not directly impacted, due largely to the long-term care industry's workforce shortages. Earlier this year, Argentum released a report showing a need to recruit more than 20 million workers by 2040 to keep pace with our rapidly aging population. We argued in our comments that imposing a minimum staffing standard will not create more caregivers; it will simply further exacerbate the current shortage.
We advised CMS to instead focus on efforts to strengthen the long-term care workforces through policies to assist in training, recruiting and retaining staff. These may include: addressing the nationwide nursing and caregiver shortages, as well as attracting both to the profession; investing in developing full-time, dedicated caregivers instead of costly agency or temporary staff that are forced upon facilities to meet a mandate; and recruiting and retaining LTC and senior living professionals by offering loan forgiveness, tax credits, apprenticeship opportunities, immigration reform and other incentives.
In addition to Argentum, the letter was signed by: the Society for Post-Acute and Long-Term Care Medicine (AMDA), American Assisted Living Nurses Association (AALNA), American Seniors Housing Association (ASHA), Association of Jewish Aging Services (AJAS), LeadingAge, Lutheran Services in America, and the National Center for Assisted Living (NCAL).
