Reminder: Contact CMS about Potential Minimum Staffing Requirements

• By: Ben Hawkins
• On: 02/09/2023 10:46:37
• In: Legislative/Government Affairs

CMS is working on creating a nationwide rule to implement a minimum staffing ratio at skilled nursing facilities. Despite Maine having its own staffing ratio requirement, this federal change could require us to hire hundreds of more employees. As we all know, finding employees right now is already hard enough. 

If you haven't contacted CMS yet, we recommend doing so by February 28. Below is an overview of how to do so. Additionally, AHCA updated the 2023 Q1 Your Top Line report on LTC Trend Tracker. This report notes your current staffing ratio, which can be used to help illustrate in your letter to CMS how much an increased requirement (which is likely to be 4.1 hours per resident day) would be an added strain on your hiring needs. Click here to learn more about how the trend tracker can enhance your testimony. 

We aim 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)
  • This is the preferred option as it helps AHCA share your testimony with other interested parties
• Or submit to healthandsafetyinquiries@cms.hhs.gov
  • Please send a copy to AHCA: gr@ahca.org 

 
Staff contact: bhawkins@mehca.org