VHCA-VCAL highlighted a series of significant concerns with the CMS proposed rule on staffing requirements for nursing facilities. In comments to the agency, VHCA-VCAL noted that:

• underfunded Medicare and Medicaid payment systems are at the root of staffing difficulties;
• the proposed rule fails to recognize that the additional clinical workers needed do not exist;
• LPNs are valuable contributors to the clinical care team and are ignored in the proposed rule; and
• CMS must rethink its approach to improving quality and staffing in nursing facilities.

Action for facilities: VHCA-VCAL encourages you to submit your own comment to CMS.

• Attend the AHCA/NCAL webinar on Friday, October 20 at 3:30 pm to get more information on how your comments can express concerns with the hours per resident day (HPRD) requirements in the proposed rule.

Read VHCA-VCAL’s comments, which also note that only 3.0 percent (1.5 percent rural) of Virginia’s long-term care facilities would meet the combined minimum staffing requirements.

• Virginia would need to add 3,544 RNs and CNAs to meet this mandate at an estimated annual cost of over $200 million (based on 2022 wages).

As a reminder, AHCA/NCAL members have access to the AHCA summary of CMS’s minimum staffing proposal and are encouraged to review it. (A member log-in is required.)

• Comments to CMS are due by November 6, 2023.
• Please email regulatory@ahca.org with any questions on the summary.