Every year brings changes to the skilled nursing industry, and operators entered 2025 with many new elements on their plate. This is where Forvis Mazars comes in. The professional services network works with providers, hospitals, physicians’ offices and community health centers (CHCs), providing financial and consultative services. Their focus this year includes changes to the facility assessment and quality measures and helping them navigate new procedures.

Here is a look at what’s new and three ways operators can prepare.

Inside the Crystal Ball: What’s New in 2025

Despite objections to the new federal nursing home staffing rule, the rule appears to be headed into practice. The federal rule stipulates that within three to five years after the publication of the final rule, varying by facility type, facilities must meet individual minimum staffing standards, including 0.55 hours per resident day (HPRD) for registered nurses and 2.45 HPRD for certified nurse aides.

The change is immense.

“These new provisions for the assessment require providers to now also reflect their present population, which means if you happen to admit somebody with a new need, this could prompt an adjustment of your minimum requirement while facility assessments must be reviewed and updated on an annual basis,” said Bob Lane, Director of Long-Term Care & Senior Living at Forvis Mazars, in a recent episode of the SNN Rethink podcast.

“However, many other providers do have referrals from hospitals that may have some different care needs, such as ventilators and dialysis, among others. This would certainly trigger the need to update your assessment and review your staffing, what resources may be needed, supplies, etc. — all of that stems from this different type of resident.”

Another change is the active involvement of RNs, LPNs, and CNAs, which Lane calls “a unique piece of language”: representatives of the direct care staff, if applicable.

“We’re reading that if a facility does have an organized labor bargaining unit as part of the organization, those representatives of the direct care staff would basically be the union,” he said.

Facility Assessment & Quality Measures Changes

One of the largest umbrella impacts of these changes is that SNFs must account for more viewpoints. SNFs must also get more input from residents and family members, Lane said, along with the RNs, LPNs, CNAs and unions. Operators have more flexibility with that input in the “how,” Lane said, whether through physical surveys, online surveys, a suggestion box or another method.

“Other changes include using the facility assessment to inform staffing decisions,” he said. “This includes competencies and skill sets that may be required. Similar to completing performance assessments of our staff and determining their training needs over the coming year based on their performance, this also needs to be directly correlated to population needs.”

This means that if a SNF has a patient with cultural and ethnic considerations, the operator must consider the sorts of additional training that staff members might need to ensure the best day-to-day interactions and care.

“If there’s a gap, of course, that would be where you would need to provide additional time and effort around competency and skill sets,” he said. “While we’re not exactly sure what they’re going to be looking for specifically, we know that the guidance does require a plan for the recruitment and retention of direct care staff to maximize the retention and their ability to fill open positions. That must be included in the facility assessment.”

Doing so may entail explaining how much you spend on advertising and how you run onboarding.

“As far as I can understand (about) the language they’ve included in the guidance, they really just want to see that you’re putting your best foot forward,” Lane said. “You’ve got some sort of intentional effort behind your recruitment and retention plan. Being able to tie your actions to some specific data that drives them will be the key, I think.”

As for quality measures, of the six that are calculated and reported on CMS’ Care Compare website, three have been around for a while. Thus Lane is helping to advise operators on the other three measures focused on staff turnover:

• The percentage of nursing staff who left over the last 12 months
• The percentage of registered nurses who left
• The number of administrators who left

He noted that the staffing domain measures are calculated separately, based on the data submitted through the provider’s payroll-based journal reports, and then reported quarterly. Those are given points for each measure, which are summed up to provide a total staffing score.

“The key here I want to emphasize is that it’s important to assure accuracy with your payroll-based journal submissions because erroneous hours are going to impact your number of points,” Lane said. “Originally, there wasn’t an impact on your score if no data was submitted on PBJ. However, now CMS has indicated that failure to submit or submit erroneous data through PBJ will result in receiving the lowest score for the turnover measures.”

Next Steps to Prepare

Lane shared several ways that these two large areas correlate. The first is that they both mandate a data-driven approach to care. The updated facility assessment and the Care Compare staffing measures use those data-driven methods to determine staffing, as well as the transparency and accountability by inclusion of staff turnover and weekend staffing measures, all of which align with the updated facility assessment’s focus on comprehensive and transparent staffing evaluations, he said.

“As far as quality of care, both sets of these updates aim to improve the quality of care in nursing facilities by assuring adequate staffing levels,” Lane said. “The minimum staffing standards in the facility assessment are reflected in the detailed staffing measures reported on Care Compare. One informs the other.”

SNFs, therefore, can first find success by ensuring the accuracy of their data.

“I think that applies on both sides: making sure that more than one set of eyes is looking at this information,” Lane said. “The facility assessment should inform all of your care delivery decisions. In lieu of a strategic plan or as a supplement, the facility assessment, even if the rest of the staffing mandate goes away, is an excellent exercise in identifying what gaps may exist in your current systems so that you can fill those to give better care.”

Lane added one final plea.

“Please take this seriously,” he said. “This is not just ‘checking the boxes.’ CMS is very intent on both of these particular programs. When they’re looking at regulatory compliance, they will be coming back to that facility assessment. The Care Compare data should align with what you reflect in your facility assessment. This could determine whether you have deficiency citations on your survey.”

This Views is sponsored by Forvis Mazars. The complexities of the Facility Assessment and the CMS Staff Turnover measures can be challenging. To learn how to connect the dots between these two requirements, contact us at www.forvismazars.us.