The National Association of State Veterans Homes (NASVH) opposes the Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting proposed rule issued by the Centers for Medicare & Medicaid Services (CMS) on September 1, 2023.
While NASVH couldn’t agree more with CMS that it is a top priority, and common goal, to ensure nursing home residents receive safe, reliable, and the utmost quality nursing home care possible, it is careless to implement a minimum staffing requirement without first addressing the feasibility and taking into consideration the health care workforce distribution and staffing shortage issues experienced in our urban and rural communities.
It’s no secret that, as a nation, we are facing historic workforce challenges and continue to struggle to find nursing staff following the “Great Resignation.” We know that staffing shortages are already impacting the access to care since nursing homes are having to turn away new admits due to lower staffing levels. Access to care has the potential to decrease even more by homes needing to continue to reduce resident admissions, along with additional unintended consequences, with this proposed minimum staffing requirement. As such, we are advocating that a proper feasibility study be conducted before this punitive mandate is enforced. We are also advocating for supplementary programs that provide additional funding and/or resources to help our State Veterans Homes recruit and retain sufficient staffing to allow more Veterans to be served by our Homes.
There is a 60-day comment period for this notice of proposed rulemaking, and comments must be submitted to the Federal Register no later than November 6, 2023. On behalf of our membership, NASVH will be submitting comment to CMS related to our concerns. We also encourage our membership to submit comment to CMS within the 60-day comment period. For more information on how to submit comments or to review the entire rule, please visit the Federal Register Federal Register :: Medicare and Medicaid Programs; Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting
Together, we are “Caring for America’s Heroes.”
Respectfully,
Tracy M. Schaner, NASVH President
