With 94% of SNFs currently failing to meet at least one threshold in the CMS-proposed rule, facilities face a binary compliance path: large-scale hiring or census reduction.
CLA Staffing Mandate Analysis – September 2023
“Although there have been improvements in workforce availability in some areas of the country, SNFs in many parts of the nation are still challenged to find the appropriate workforce. Some facilities may need to reduce admissions or number of beds in a facility to meet staffing ratios. If SNFs are unable to increase their workforce, hundreds of thousands of residents could be impacted by census reductions.”
Citation: CliftonLarsonAllen. CLA Staffing Mandate Analysis – September 2023. Prepared for the American Health Care Association, Sept. 2023, www.ahcancal.org/News-and-Communications/Fact-Sheets/FactSheets/CLA%20Staffing%20Mandate%20Analysis%20-%20September%202023.pdf.
Price of nursing home staffing mandate is $6.8B, 100K more workers, analysis finds
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. When nearly every nursing home in the country would be considered out of compliance if this went into effect today, it demonstrates how out of touch Washington bureaucrats are with reality.”
— McKnight’s Long-Term Care News, September 26, 2023
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. 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.”
— Fierce Healthcare, September 26, 2023
The proposed rule requires 2.45 CNA hours per resident per day (HPRD) and 0.55 RN HPRD, and for facilities to have an RN on site 24 hours per day.
“There are two ways to meet the staffing mandate. One is to increase staff, the other is to decrease the number of residents in the facility. Those are the only two levers that can be pulled.”
— Skilled Nursing News, September 26, 2023
As forecast price of federal staffing mandate climbs to $11.7B, analysts offer alternatives
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, 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.”
— McKnight’s Long-Term Care News, August 28, 2023
Potential staff mandate costs rocket upward when latest wages factored in
In Thursday’s report, CLA found 94% of nursing homes would be unable to comply with a potential 4.1 hours per day staffing minimum, and that almost 450,000 residents might be displaced if facilities aren’t able to boost their workforces and thus have to reduce their census in order to meet a 4.1 hours per day minimum.
“The additional burden of meeting minimum staffing requirements with no funding mechanism will potentially increase the number of facilities operating with negative margins. Although there have been improvements in workforce availability in some areas of the country, nationally, nursing homes are still challenged to find the appropriate workforce.”
— McKnight’s Long-Term Care News, December 16, 2022
$11.3 Billion Needed to Meet Proposed Federal Minimum Staffing Mandate
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. That report initially estimated that an additional 187,000 caregivers and an annual cost of $10 billion would be required to fulfill the staffing mandate.
“This report once again highlights how our nation’s policymakers should be investing in our long term caregivers, not mandating quotas. Nursing homes have been doing everything they can to recruit and retain staff — including increasing wages — but it has not been enough to stem the tide. If Washington wants to increase staffing in nursing homes, then they need to put their money where their mouth is.”
— Skilled Nursing News, December 15, 2022
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.
“The single biggest thing that I’m worried about is an unfunded 4.1 mandate … if that occurs [it] would be lights out for multiple facilities across the country.”
— Skilled Nursing News, August 22, 2022
Minimum Staffing Requirements Could Cost Nursing Homes $10B Annually
“This report makes it crystal clear that increasing staffing standards in nursing homes requires substantial and consistent government resources. The unintended consequences of this sort of unfunded mandate would be devastating to hundreds of thousands of vulnerable residents who could be forced out of their nursing home.”
— RevCycle Intelligence, July 20, 2022
Mandated minimum staffing would cost nursing homes $10 billion annually
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. Many facilities will have to make difficult decisions, such as reducing census, to meet the proposed staffing minimums.”
— McKnight’s Long-Term Care News, July 20, 2022
Federal Staffing Minimums Could Cost the Nursing Home Industry $10B
“Even then, nursing homes would have the impossible task of finding another 187,000 nurses at a time when vacant positions sit open without applicants for months on end. The unintended consequences of this sort of unfunded mandate would be devastating to hundreds of thousands of vulnerable residents who could be forced out of their nursing home.”
— Skilled Nursing News, July 19, 2022
