Contact CMS: Minimum Staffing Requirements for Skilled Nursing Facilities

• By: Ben Hawkins
• On: 01/26/2023 12:37:21
• In: National Affiliate News

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 educate@ahca.org 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:

• Send through AHCA/NCAL website (https://www.votervoice.net/AHCA/Campaigns/99591/Respond)
• Or submit to healthandsafetyinquiries@cms.hhs.gov
  • Please send a copy to AHCA: gr@ahca.org 

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: bhawkins@mehca.org