AHCA & CliftonLarsonAllen Study the Cost of Minimum Staffing Proposals

Sep 30, 2023 | Minimum Staffing, Research Studies of PBJ Data

News Digest: AHCA and CliftonLarsonAllen Study the Cost of Minimum Staffing Proposals

The cost of staffing to meet a minimum staffing mandate is estimated to be between $3.8 billion and $11.3 billion, depending on the scenario. The CLA 37th Annual SNF Cost Comparison and Industry Trends report identified 7,741 out of 13,193 SNFs (59%) that had negative operating margins (excluding public health emergency funding). The additional burden of meeting minimum staffing requirements with no funding mechanism could potentially increase the number of facilities operating with negative margins.

In addition to the cost of meeting a staffing mandate, the SNF industry would need to hire between 58,000 and 191,000 additional full-time equivalents (FTEs). Although there have been improvements in workforce availability in some areas of the country, nationally SNFs are still challenged to find the appropriate workforce. Some facilities may need to reduce admissions or number of beds in a facility in order to meet staffing ratios.

Updated September, 2023

Updated December, 2022

First Published July, 2022

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AHCA: Staffing Proposal to Cost $6.8B Per Year, Create Access Issues for Nearly One Quarter of Nursing Home Residents

More than 280,000 residents, or nearly a quarter of all residents, could be impacted by the staffing mandate – if nursing home operators have no choice but to reduce their census in order to meet hourly requirements.

The proposed federal mandate would require an estimated 102,154 additional full-time employees. That’s 80,077 certified nursing assistants (CNAs) and 22,077 registered nurses (RNs), according to an analysis released Tuesday by the American Health Care Association (AHCA) and prepared by professional services firm CliftonLarsonAllen (CLA).

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Stulick, Amy. “AHCA: Staffing Proposal to Cost $6.8B per Year, Create Access Issues for Nearly One Quarter of Nursing Home Residents.Skilled Nursing News, Sept. 2023, skillednursingnews.com/2023/09/ahca-staffing-proposal-to-cost-6-8b-per-year-create-access-issues-for-nearly-one-quarter-of-nursing-home-residents.

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CMS' staffing proposal will cost nursing homes $6.8B for 102K nurse hires, industry-backed report finds

Meeting the Biden administration’s minimum staffing proposals for nursing homes would require facilities nationwide to hire more than 102,000 additional nurses at a cost of $6.8 billion, well above the government’s $4 billion estimate, according to a report released Tuesday by an industry group.

“That is money that is simply not out there,” Mark Parkinson, president and CEO of the American Health Care Association (AHCA) and its sister organization the National Center for Assisted Living, said during a press event Tuesday. “Even at the administration’s number of $4 billion—that’s almost $400,000 per nursing facility, and nursing facilities just don’t have that money. They will not be able to implement this proposal.”

Earlier this month, the Centers for Medicare & Medicaid Services (CMS) floated a plan to require participating nursing homes to provide a minimum of 0.55 hours of care from a registered nurse per resident per day, 2.45 hours of care from a nurse aide per resident per day and have at least one registered nurse on-site at all times.

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“CMS’ Staffing Proposal Will Cost Nursing Homes $6.8B for 102K Nurse Hires, Industry-backed Report Finds.Fierce Healthcare, 26 Sept. 2023, www.fiercehealthcare.com/providers/cms-staffing-proposal-will-cost-nursing-homes-68b-102000-new-nurse-hires-industry-backed

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BREAKING: Price of nursing home staffing mandate is $6.8B, 100K more workers, analysis finds

Nursing homes would need to spend more than $6.8 billion annually to meet a proposed federal staffing mandate, which also would require them to hire more than 102,000 new workers if enacted as originally introduced, according to an analysis updated Tuesday by accounting and consulting firm CliftonLarsonAllen.

That projected cost is nearly 60% higher than the $4 billion annual cost estimated by the Centers for Medicare & Medicaid Services in a draft rule it issued Sept. 1. The CLA analysis was conducted in conjunction with the American Health Care Association/National Center for Assisted Living.

“What CLA’s analysis confirms is that this proposed rule is deeply flawed, and the Biden  Administration has woefully underestimated the feasibility and cost of this unfunded mandate,”  AHCA President and CEO Mark Parkinson said in advance of the analysis’ release this morning.

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Marselas, Kimberly. “[Updated] BREAKING: Price of Nursing Home Staffing Mandate Is $6.8B, 100K More Workers, Analysis Finds.” McKnight’s Long-Term Care News, Sept. 2023, www.mcknights.com/news/breaking-price-of-nursing-home-staffing-mandate-is-6-8b-100k-more-workers-analysis-finds.

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Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact

In April 2022, CMS released the proposed rule for the SNF PPS Payment updates for Federal Fiscal Year 2023 (FFY23). In the proposed rule, CMS is seeking input regarding the establishment of a minimum staffing requirement for Long Term Care (LTC) facilities. CMS has “long identified staffing as one of the vital components of a nursing home’s ability to provide quality care…”

The initial analysis compares the potential cost to the LTC industry for meeting a minimum staffing requirement at three different levels: 4.1 Hours Per Patient Day (HPPD), 3.6 HPPD and 3.1 HPPD. Utilizing Payroll Based Journal (PBJ) data and hourly rates from Medicare cost reports, we have identified the additional staff necessary to meet the staffing requirement, as well as the costs associated with the additional staff.

The September 2023 update changed to using CMS’ proposed staffing levels of 3.0 HPPD and compared itself as 60% higher industry cost than CMS identifies as the industry cost in its proposed rule.

READ LATEST ANALYSIS

Updated Sep. 2023:
“Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact.” CliftonLarsonAllen, 20 Sep. 2023,
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA%20Staffing%20Mandate%20Analysis%20-%20September%202023.pdf

Updated Dec. 2022:
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis-Dec2022.pdf

First Published Jul. 2022:
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis.pdf

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As forecast price of federal staffing mandate climbs to $11.7B, analysts offer alternatives

The price tag is going up on a potential federal staffing mandate.

A standard of 4.1 hours per patient per day could cost the skilled nursing sector $11.7 billion annually, according to an updated analysis by consulting and advisory firm CliftonLarsonAllen.

That’s up from a projected $11.3 billion in January, and an increase of $1.7 billion in the 13 months since CLA issued its first estimate in mid-2022.

The potential cost has been pushed higher by inflation and continued wage pressures, as the current staffing shortage continues to play out nationwide.

“People are starting to make the connection to say, if we implement the staffing mandate, that problem is going to get way worse,” said Cory Rutledge (pictured), chief assurance officer at CliftonLarsonAllen. “As we sit here today, less than 10% of skilled nursing facilities are at 4.1 hours per patient day. … There are really two levers to pull to get to a 4.1: You either hire a lot more people, which don’t exist … or you discharge residents to decrease the denominator.”

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Marselas, Kimberly. “As Forecast Price of Federal Staffing Mandate Climbs to $11.7B, Analysts Offer Alternatives.” McKnight’s Long-Term Care News, 28 Aug. 2023, www.mcknights.com/news/as-forecast-price-of-federal-staffing-mandate-climbs-to-11-7b-analysts-offer-alternatives/. Accessed 2 Oct. 2023.

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Potential Staff Mandate Costs Rocket Upward When Latest Wages Factored In

The projected costs of meeting a possible nursing home staffing mandate have skyrocketed by $1.3 billion over the last five months, a report issued Thursday by accounting firm CliftonLarsonAllen on behalf of the American Health Care Association found.

In July, CLA issued initial projections. The latest report uses updated Payroll Based Journal and Medicare cost report data.. Due to higher labor costs and persistent staff shortages across the US, CLA now estimates more than 191,000 nurses and nurse’s aides are needed at the annual cost of $11.3 billion if nursing homes are to meet a staffing minimum of 4.1 hours per patient day. That’s up from original estimates of 187,000 caregivers and a yearly cost of $10 billion.

During the pandemic, nursing homes lost more workers than any other healthcare category — over 200,000, according to the Bureau of Labor Statistics. Skilled nursing providers are the only ones in healthcare still struggled to get back to pre-pandemic levels, despite aggressive hiring campaigns and rising wages.

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Bush, Joe. “Potential Staff Mandate Costs Rocket Upward When Latest Wages Factored In.” McKnight’s Long-Term Care News, 16 Dec. 2022, www.mcknights.com/news/potential-staff-mandate-costs-rocket-upward-when-latest-wages-factored-in.

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$11.3 Billion Needed to Meet Proposed Federal Minimum Staffing Mandate

Due to increased labor costs and nationwide workforce shortages, 191,000 nurses and nurse aides are needed at the annual cost of $11.3 billion in order for nursing homes to meet a staffing minimum of 4.1 hours per resident day (HPRD).

That’s according to the American Health Care Association (AHCA) and CliftonLarsonAllen, an accounting and consulting firm, which on Thursday released an update to a July 2022 report. 

Among other findings in the updated report, researchers concluded that 94% of nursing homes would be unable to comply with a potential 4.1 HPRD staffing minimum, and that nearly 450,000 residents may be at risk of displacement if facilities are unable to increase their workforce and must reduce their census in order to comply with minimums.

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Grebbin, S. (2022, December 15). $11.3 Billion Needed to Meet Proposed Federal Minimum Staffing Mandate. Skilled Nursing News. https://skillednursingnews.com/2022/12/11-3-billion-needed-to-meet-proposed-federal-minimum-staffing-mandate/

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Price of proposed nursing home staffing mandate? Try $11.3B a year, new AHCA report finds

The American Health Care Association Thursday released an updated report from accounting and consulting firm CliftonLarsonAllen detailing the costs of a potential federal staffing mandate for America’s nursing homes.

“Unfunded staffing mandates do not create jobs or attract individuals to apply,” Holly Harmon, RN, AHCA’s senior vice president of quality, regulatory and clinical services, said in a statement. “ Investing in our caregivers, developing recruitment programs, and building a pipeline of caregivers will help us rebuild the long-term care workforce.”

“If Washington wants to increase staffing in nursing homes, then they need to put their money where their mouth is. Otherwise, we’ll fail to address the underlying issue here, and our residents will have fewer long-term care options,”  Harmon said.

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Gaivin, Kathleen Steele. “Price of Proposed Nursing Home Staffing Mandate? Try $11.3B a Year, New AHCA Report Finds.” McKnight’s Senior Living, 17 Dec. 2022, www.mcknightsseniorliving.com/home/news/business-daily-news/price-of-proposed-nursing-home-staffing-mandate-try-11-3b-a-year-new-ahca-report-finds.

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Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact

In April 2022, CMS released the proposed rule for the SNF PPS Payment updates for Federal Fiscal Year 2023 (FFY23). In the proposed rule, CMS is seeking input regarding the establishment of a minimum staffing requirement for Long Term Care (LTC) facilities. CMS has “long identified staffing as one of the vital components of a nursing home’s ability to provide quality care…”

The December analysis compares the potential cost to the LTC industry for meeting a minimum staffing requirement at three different levels: 4.1 Hours Per Patient Day (HPPD), 3.6 HPPD and 3.1 HPPD. Utilizing Payroll Based Journal (PBJ) data and hourly rates from Medicare cost reports, we have identified the additional staff necessary to meet the staffing requirement, as well as the costs associated with the additional staff.

The December update labor costs and staffing gaps to current market conditions.

Updated Dec. 2022:
“Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact.” CliftonLarsonAllen, 20 Dec. 2022,
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis-Dec2022.pdf

First Published Jul. 2022: READ ORIGINAL ANALYSIS
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis.pdf

Updated Sep. 2023:
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA%20Staffing%20Mandate%20Analysis%20-%20September%202023.pdf

 

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A minimum staffing rule can work. Here’s what it will take: Parkinson

The nation’s most influential nursing home leader says the White House’s goal of imposing first-ever minimum staffing levels could work — but only under certain conditions.

They include supplying more funding, considering local workforces in calculations and making waivers available. Providers said waivers have been vital for complying with the federal healthcare worker COVID-19 vaccination mandate.

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Berklan, James. “A Minimum Staffing Rule Can Work. Here’s What It Will Take: Parkinson.” McKnight’s Long-Term Care News, 22 Aug. 2022, www.mcknights.com/news/a-minimum-staffing-rule-can-work-heres-what-it-will-take-parkinson.

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AHCA’s Parkinson: Unfunded Federal Staffing Mandate Would Be ‘Lights Out’ For Nursing Homes Across The Country

The federal government provided relief to the nursing home industry in the form of a phased-in parity adjustment and a 2.7% pay bump, but a potentially enormous obstacle still stands in the way of the sector’s recovery.

While many industry leaders believe a federal staffing ratio is all but guaranteed, the Centers for Medicare & Medicaid Services (CMS) has remained tightlipped on what exactly that might look like.

An unfunded daily minimum standard of 4.1 hours would put essentially every nursing home building in the country out of compliance, American Health Care Association President and CEO Mark Parkinson warned.

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Reiland, Jordyn. “AHCA’s Parkinson: Unfunded Federal Staffing Mandate Would Be ‘Lights Out’ for Nursing Homes Across the Country.” Skilled Nursing News, 22 Aug. 2022, skillednursingnews.com/2022/08/ahcas-parkinson-unfunded-federal-staffing-mandate-would-be-lights-out-for-nursing-homes-across-the-country.

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CLA’s Deb Emerson on staffing mandates and ‘wishful thinking’

In this Newsmakers Podcast, McKnight’s Long-Term Care News staff writer Danielle Brown sits down with Deb Emerson, principal at accounting and consulting firm CliftonLarsonAllen LLP. They discuss CLA’s recent analysis on the impact a minimum staffing requirement would have on nursing homes

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Brown, Danielle. “CLA’s Deb Emerson on Staffing Mandates And ‘Wishful Thinking.’” McKnight’s Long-Term Care News, 10 Aug. 2022, www.mcknights.com/news/wishful-thinking-to-believe-a-minimum-staffing-mandate-for-nursing-homes-can-be-rolled-out-efficiently-not-cost-providers-significantly.

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CMS Proposed Minimum Staffing Requirements Could Cost $10B Annually

Nursing homes and long-term care (LTC) facilities need to increase staffing minimums at the federal level and that expansion might cost $10 billion dollars annually according to The American Health Care Association and National Center for Assisted Living (AHCA/NCAL). The AHCA/NCAL published a new report titled, “Staffing Mandate Analysts In-depth Analysis on Minimum Nurse Staffing Levels and Local Impact” released from accounting and consulting firm CLA (CliftonLarsonAllen LLP).

The report was in response to the Centers for Medicare and Medicaid Services’ (CMS’) report released in April 2022, with the proposed rule for the skilled nursing facilities per diem prospective payment system, payment updates for Federal Fiscal Year 2023. In the proposed rule, CMS is seeking input regarding the establishment of a minimum staffing requirement for LTC facilities.

The report says that the funds would hire 187,000 nurses and nurse aids at 4.1 hours per resident day in 94% of LTC facilities to comply with the requirement in caring for more than 900,000 residents.

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Whitacre, Tori. “CMS Proposed Minimum Staffing Requirements Could Cost $10B Annually.” Infection Control Today, 3 Aug. 2022, www.infectioncontroltoday.com/view/cms-proposed-minimum-staffing-requirements-could-cost-10b-annually.

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Minimum Staffing Requirements Could Cost Nursing Homes $10B Annually

More than 200,000 residents could be at risk of displacement if federal leaders establish minimum staffing requirements for nursing homes.

Nursing homes would have to spend up to $10 billion per year and hire almost 188,000 nurses to comply with increased minimum staffing requirements, according to a report from the American Health Care Association (AHCA) and accounting and consulting firm CLA (CliftonLarsonAllen LLP).

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Baily, Victoria. “Minimum Staffing Requirements Could Cost Nursing Homes $10B Annually.” Revcycle Intelligence, 20 Jul. 2022, revcycleintelligence.com/news/minimum-staffing-requirements-could-cost-nursing-homes-10b-annually.

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Federal Staffing Minimums Could Cost the Nursing Home Industry $10B

Establishing minimum staffing requirements at the federal level, like what the White House proposed back in February, may require nursing home providers to spend billions of dollars each year to hire tens of thousands of additional staff.

That’s according to a new report from accounting and consulting firm CliftonLarsonAllen (CLA) in concert with the American Health Care Association (AHCA).

The analysis specifically modeled the impact that implementing a staffing minimum of 4.1 hours per resident day (HRPD) could have on the industry, in addition to 3.6 HRPD and 3.1 HRPD.

READ FULL ARTICLE

Reiland, Jordyn. “Federal Staffing Minimums Could Cost the Nursing Home Industry $10B.” Skilled Nursing News, 19 July 2022, skillednursingnews.com/2022/07/federal-staffing-minimums-could-cost-the-nursing-home-industry-10b.

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Mandated minimum staffing would cost nursing homes $10 billion annually

Providers would have to spend an additional $10 billion more per year and hire more than 187,000 new workers to meet requirements of one possible federal minimum staffing approach, according to a new analysis.

The findings prove that nursing homes would need “substantial and consistent government resources” to comply with the regulations, the nation’s largest nursing home association said.

“Every staffing minimum scenario we analyzed found that tens of thousands of additional full-time employees as well as billions of dollars each year would be necessary in order for nursing homes to be in compliance,” said Deb Emerson, principal at CliftonLarsenAllen. “Many facilities will have to make difficult decisions, such as reducing census, to meet the proposed staffing minimums.”

READ FULL ARTICLE

Brown, Danielle. “Mandated Minimum Staffing Would Cost Nursing Homes $10 Billion Annually.” McKnight’s Long-Term Care News, 20 July 2022, www.mcknights.com/news/mandated-minimum-staffing-would-cost-nursing-homes-10-billion-annually.

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Minimum staffing levels would cost nursing homes $10 billion a year: report

The federal government’s proposed minimum staffing requirements for nursing homes could cost the industry $10 billion a year because tens of thousands of additional caregivers would need to be hired, according to a new report from accounting and consulting firm CliftonLarsonAllen.

Further, fewer slots may be available for residents and patients as some facilities reduce their census to meet the staffing requirement, the report maintains. The report was released Tuesday by the American Health Care Association.

The Centers for Medicare & Medicaid Services is considering requiring nursing homes to implement staffing minimum of 4.1 hours per resident day. The proposal comes as part of President Joe Biden’s nursing home reform initiatives.

READ FULL ARTICLE

Gaivin, Kathleen Steele. “Minimum Staffing Levels Would Cost Nursing Homes $10 Billion a Year: Report.” McKnight’s Senior Living, 20 July 2022, www.mcknightsseniorliving.com/home/news/business-daily-news/minimum-staffing-levels-would-cost-nursing-homes-10-billion-a-year-report.

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Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact

In April 2022, CMS released the proposed rule for the SNF PPS Payment updates for Federal Fiscal Year 2023 (FFY23). In the proposed rule, CMS is seeking input regarding the establishment of a minimum staffing requirement for Long Term Care (LTC) facilities. CMS has “long identified staffing as one of the vital components of a nursing home’s ability to provide quality care…”

The initial analysis compares the potential cost to the LTC industry for meeting a minimum staffing requirement at three different levels: 4.1 Hours Per Patient Day (HPPD), 3.6 HPPD and 3.1 HPPD. Utilizing Payroll Based Journal (PBJ) data and hourly rates from Medicare cost reports, we have identified the additional staff necessary to meet the staffing requirement, as well as the costs associated with the additional staff.

READ FULL ANALYSIS

First Published Jul. 2022:
“Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels and Local Impact.” CliftonLarsonAllen, 18 Jul. 2022, https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis.pdf

Updated Dec. 2022:
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA-Staffing-Mandate-Analysis-Dec2022.pdf

Updated Sep. 2023:
https://www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA%20Staffing%20Mandate%20Analysis%20-%20September%202023.pdf

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