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Time is Running Out: Please Send a Letter to CMS Regarding the Proposed Minimum Staffing Mandate

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  • Time is Running Out: Please Send a Letter to CMS Regarding the Proposed Minimum Staffing Mandate
February 24, 2023

MSCA has joined with AHCA in their advocacy efforts to halt a potential CMS minimum staffing mandate that may be as high as 4.1 hours per patient day (HPPD). To date, only 28 members from Massachusetts nursing facilities have submitted letters to CMS and we need at least 100 letters sent by the February 28th deadline.  We urge all members to submit comments by February 28, 2023 following the instructions outlined by AHCA.

While Mass Senior Care Association (MSCA) shares the Administration’s goal of increasing staff in nursing facilities in order to ensure the safety and well-being of our residents, we are extremely concerned that a 4.1 HPPD mandate during a historic workforce crisis would have a disastrous impact on access to quality nursing home care at a time when qualified caregivers are in short supply and state and federal reimbursement already underfunds the sector. 

Important points to consider in letters coming from Massachusetts nursing facilities include but are not limited to:

  1. Massachusetts already has a minimum HPPD requirement of 3.58, and a large number of facilities have been unable to achieve the current state standard given the lack of supply of licensed nurses and certified nursing assistants.
  2. 1 in 5 caregiving positions is vacant in Massachusetts nursing facilities despite significant efforts by facilities to hire qualified staff; and 
  3. Even if the additional caregivers were available to hire, nursing homes do not have adequate funding to pay for this level of additional staff.  

AHCA/NCAL recorded a free webinar providing an overview of the issue (requires registration/facility membership), and step by step guidance on crafting an effective letter to key decision makers.

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