Premier Comments on Long-term Care Facility Minimum Staffing Proposed Rule

Premier submitted comments on the Centers for Medicare & Medicaid Services' proposed rule on minimum staffing for long-term care facilities. In detailed comments, Premier urged CMS to:

  • Not finalize its current proposal at this time and work with stakeholders to further study and understand the impact of staffing ratios on access to quality care for residents;
  • Advance a multi-pronged policy approach to holistically address healthcare workforce challenges;
  • Develop policies that incentivize long-term care (LTC) facility and post-acute providers to implement electronic health records and electronic clinical surveillance technology to provide meaningful assistance with infection control;
  • Consider streamlining the process for hardship exemptions, extending the exemption time period, and adding an exemption for unforeseen circumstances; and
  • Abandon the proposal for state Medicaid reporting and focus on reporting channels already in place, such as the skilled nursing facility (SNF) Quality Reporting Program (QRP), that can provide facility level data on staffing and patient outcomes.

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Date Published:
10/30/23
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