Staffing Mandate Analysis on Minimum Nurse Staffing Levels

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 following 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.