The Centers for Medicare & Medicaid Services (CMS) should not implement the proposed nursing home staffing mandate for numerous reasons, including that “numerical staffing staffing thresholds are not consistent with the modern clinical practice.”
That’s according to the American Hospital Association (AHA), which commented on the proposed mandate on behalf of its nearly 5,000 member hospitals, 2,425 post-acute care members, and other constituencies.
“A simple mandate of a base number of RN and NA hours per resident day emphasizes staff roles and responsibilities of yesterday rather than what current and emerging practices may show is most effective and safe for the patient and best aligned with the capabilities of the care team,” wrote AHA Executive Vice President Stacey Hughes, author of the organization’s comment letter.
The comment described “emerging care models” that involve nurses at various levels of licensure but also a variety of other caregivers and clinicians, such as therapists in a variety of specialties.
The AHA is also “greatly concerned that these rigid standards would stymie innovation in care delivery,” Hughes wrote. Specifically, Covid-19 led hospitals and post-acute care providers to pursue new models of care and leverage technology in novel ways, and staffing mandates could compromise efforts to test and refine such models, which hold the potential to improve patient outcomes and staff satisfaction.
The hospital association also echoed many of the concerns voiced by nursing home industry leaders in recent weeks, including fears that the staffing mandate would worsen existing workforce shortages across the health care continuum and harm consumer access to care.
And the association offered – as a “starting point” – ideas for alternative approaches that might help to meet CMS’ goals in pursuing the mandate. These suggestions included several standards around assessing nursing homes on how they set and comply with their own staffing policies. For example:
“Nursing homes could be asked to ensure they have established processes for attempting to bring in additional staff to meet an unexpected change in patient mix or shortage during a particular shift. They also could be asked to describe any processes to ‘flex’ staff to other parts of the organization, or even how they may choose to physically position staff within a facility to ensure safety.”
Such an approach could also take into account the facility’s technological capabilities, and importantly would shift operators’ focus into more fruitful directions rather than being preoccupied with meeting a one-size-fits-all threshold, the AHA argued.
“Instead of being forced by CMS to focus on the question, ‘How do we achieve the minimum staffing threshold,’ nursing homes could instead focus on the far more important questions of ‘What is our ongoing process for safely staffing our facility? How do we respond when we experience staffing shortages or unexpected changes to our patient mix?’” Hughes wrote.
Companies featured in this article:
American Hospital Association, Centers for Medicare & Medicaid Services, CMS
