CMS Outlines Multi-Faceted Approach to Nursing Home Minimum Staffing Requirements

Nursing home operators finally got a peek behind the curtain after the federal government announced an initiative to establish minimum staffing requirements back in February.

In an industry stakeholder call on Wednesday, Centers for Medicare & Medicaid Services (CMS) Social Science Research Analyst Pauline Karikari-Martin said the agency is using a “multi-faceted” approach to proposing a minimum staffing ratio – stakeholder commentary tied to the SNF Prospective Payment System (PPS), a long-awaited study and listening sessions to be held in August.

The listening sessions will be used to inform the agency’s research study design, according to Karikari-Martin.

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The “mixed methods” research study will assess the minimum staffing requirements needed to ensure that residents receive safe and quality care, she added.

“While we are still working on the final methodology for this study, we can say that together the quantitative and qualitative analysis research will inform our draft proposals on minimum staffing requirements in nursing homes in 2023,” said Karikari-Martin.

When the initiative was announced in February, the agency said they were planning on conducting a study to determine the right number of hours for a minimum staffing ratio, to be completed within a year.

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“This is an incredibly important body of work that will help to ensure that nursing home residents are receiving safe and quality care that they need,” said Karikari-Martin. “We know that everyone listening to today’s call has diverse experience … we encourage you to provide additional feedback on aspects we should consider or any evidence that you may have that could be useful in informing our overall approach.”

Why now?

The agency is acting now on a minimum staffing ratio, along with other staffing-related updates tied to the five-star rating and surveys, simply because it’s been proven that adequate staffing impacts quality, according to Evan Schulman, CMS division of nursing homes director.

“We now know that staff turnover does have an impact on quality and that really serves as another tool in addition to raising staffing levels that nursing homes can use to improve quality,” said Schulman. “The moment that we learn of a new way to improve quality, we want to put that information out as soon as possible.”

Guidance on staffing measures tied to the five-star rating system were released last week, as CMS updated its staffing measures to include three on staffing levels and three on staff turnover.

Total nurse staffing hours per resident per day on weekends, in addition to previously announced nurse turnover within a given year, annual registered nurse turnover and annual number of administrators who left the sector will be incorporated into staffing measures.

Families and residents deserve to know the level of staffing and quality that each nursing home provides, added Schulman.

“We’re really trying to use everything we can to improve how we report quality, how we improve staffing,” he said.

CDC recommendations

Representatives with the Centers for Disease Control and Prevention (CDC) joined the call as well, outlining updated recommendations for enhanced barrier precautions (EDP) against multidrug-resistant organisms (MDROs) in nursing homes.

Use of a gown and gloves should be applied more broadly in the nursing home, Kara Jacobs Slifka told listeners, rather than only during a “novel and targeted” MDRO outbreak.

“EDP involves the use of a gown and gloves during high contact resident care activities,” said Jacobs Slifka. “This includes dressing; bathing or showering; performing transfers; changing linens; providing hygiene; assisting with toileting; care of a medical device such as a central line urinary catheter, feeding tube or tracheostomy tube; as well as when performing wound care on any skin opening that requires a dressing.”

CDC and CMS were quick to point out that the updates were not new regulations for the industry.

Jacobs Slifka said the EDP suggestion should be used for a resident’s entire length of stay, or until a medical device is removed or wounds have resolved.

The recommendation is also an effort to reduce the spread of MDROs without isolating residents for long periods of time, she said, while also acknowledging that a large number of residents – larger than initially anticipated – can remain “colonized.”

She refers to clusters of germs living on or in the body while not actually being sick with an infection. While documented MDRO cases were 17%, actual MDRO spread was closer to 58% – more than half of residents.

“The problem with MDROs is much larger and so focusing only on interventions for residents with an active infection is not sufficient,” added Jacobs Slifka.

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