The Centers for Medicare & Medicaid Services (CMS) proposed the first ever nursing home staffing mandate on September 1, 2023. According to the proposed rule, U.S. nursing homes will have at least three years to provide a minimum of 3.0 hours per patient day of direct care, .55 hours of that by a registered nurse (RN), and 2.45 hours by a nurse aide. The mandate also calls for an RN to be on-site 24/7. Non-rural nursing homes have three years to comply with this rule and rural facilities will have five years. Although the mandated per day levels are below the 4.1 hours per day that CMS recommended in 2001, 75 percent of nursing homes would need to add staffing to reach the proposed compliance levels, according to CMS.[1]
ADDITIONAL PROPOSED CHANGES
Apart from the requirement for adequate staffing, there are proposed changes to the facility assessment processes. Facilities must use evidence-based methods in care planning including behavioral health needs of residents. They must also conduct an assessment of each resident’s specific adjustments for that population and develop a staffing plan to maximize recruitment and retention of staff. These revisions are set to take effect 60 days following the formalization of the rule. There are also new proposed institutional payment reporting requirements that require states to report to CMS on the percentage of nursing home Medicaid payments “spent on compensation for direct care workers and support staff.”[2] All of this will be enforced through the existing survey process.
The hope in establishing minimum staffing levels for nursing homes is that it will improve resident safety and promote a higher quality of care. Many providers, however, are disappointed that President Biden decided to push through the proposed staffing ratios.[3]
HOW CAN YOU PREPARE?
Even if some in the industry are up in arms about the mandate, it is important to prepare for the future. The focus needs to be on recruiting and retention programs, investing in sustainable programs to cultivate a pipeline of qualified candidates and working with vendors and partners to create a robust and strategic recruitment marketing campaign so you continuously have candidates available to hire.
An applicant tracking system (ATS) won’t cut it, relying on agency alone won’t cut it, and waiting until the rule is finalized also won’t cut it. You need expertise, as well as a strategy to keep your candidates informed and moving forward timely in the hiring and onboarding process so they are available when you need them. You also need to revisit and invest in your retention programs. It’s important to keep your current talent happy and feeling valued.
This may all seem daunting, but there are three to five years to prepare for these staffing mandates, so let’s not take our foot off the gas. The time is now to start discussing, strategizing, and finding the right tools and resources to meet the requirements ahead of us.
For further insight into these strategies, we recommend you read the following HDG blog posts:
- “Culture Change: A Sustainable Solution to Rebuilding And Re-Engaging Your Workforce”
- “A Strategic Focus to Managing Employee Retention”
- “Crafting a Culture of Meaningful Work”
- “Workforce Stability: Stimulating Engagement Amidst Disruption”
- “A Novel Idea: Investing in Employee Strengths”
HDG CAN HELP
At Health Dimensions Group (HDG), we understand the complexity of these issues and the difficulty of finding quality staff members. However, through HDG’s workforce solutions, you can ensure you will be prepared when the mandate goes into effect. For more information, please contact us at info@hdgi1.com or 763.537.5700.
