Contact CMS: Minimum Staffing Requirements for Skilled Nursing Facilities

AHCA/NCAL recently hosted a webinar to discuss the importance of and tips on contacting CMS to weigh in on proposals the agency is writing for SNF minimum staffing requirements. Presenters included AHCA/NCAL President and CEO Mark Parkinson and Senior Director, Grassroots Program Matthew Smyth.

The recorded webinar is now available for AHCA/NCAL members. Please log in and register for the webinar in order to view it.
Email if you need assistance with registering or have any questions.

Click here to access the webinar.  

Summary of the webinar:

Mark Parkinson says the staffing minimum requirement is the worst public policy idea he has seen in the past 12 years. CMS is going to issue a staffing proposal around May 1.
AHCA's goal is to shape the proposal before it comes out on May 1. 
  • AHCA asks we submit a comment by February 28. 
  • All NF staff, including frontline workers, are encouraged to submit comments
They want us to contact CMS to weigh in on their upcoming proposal. 
  • Make comments personalized to drive home message.
    • Use own circumstances and examples
  • Focus on our patients and residents 
Talking points
  • Explain who you are
    • What you do & how long you have been in this line of work
    • Why you work in LTC
    • Describe your building
      • Location, # of units. profile of your residents' needs
  • Your commitment to quality
    • Mention any AHCA Quality Award or other award you have received
    • Explain what your residents mean to you and your team 
  • Workforce not available
    • Explain how difficult it is to get workers
    • Recruitment challenges
      • How many open positions
      • Inability to fill shifts
  • Asks of CMS 
    • Don't do this.
      • Or if they do it, then phase it in as the workforce comes back 
    • Any requirement must be paid entirely by Medicaid and Medicare
    • Include a broad definition of staff under the requirement
      • Staff other than nurses still offer valuable care to our residents
    • Note that LTC sector still trying to recover from the COVID pandemic 
How to do it: AHCA/NCAL encourages sending comments through their website. AHCA/NCAL will use their messaging database to ensure all other relevant officials also get our note. 
Staff contact: