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

Updated September 2023 | Updated December 2022Published July, 2022

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On April 11, 2022, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities for Fiscal Year 2023. Of particular interest, CMS opened up the Minimum Staffing debate with a specific request for input on establishing minimum staffing requirements for LTC facilities.

The largest nursing home association, AHCA, together with a prominent industry consultant CliftonLarsonAllen, completed a financial cost analysis of CMS’ FY 2023 Proposed Rule to evaluate the financial impact upon the skilled nursing industry.

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.

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