In response to the Department of Health and Human Service (HHS) Centers for Medicare and Medicaid Services (CMS) proposed rule CMS-1765-P Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2023; Request for Information on Revising the Requirements for Long-Term Care Facilities To Establish Mandatory Minimum Staffing Levels published in the Federal Register on April 15, 2022, SDAHO submitted comments reflecting the feedback from members on the devastating impact mandatory staffing levels will have on the nursing homes in South Dakota. “When it comes to staffing and quality of care in a nursing home, one size does not fit all” states Tammy Hatting, COO at SDAHO. Many factors have to be taken into consideration such as size of the facility, staff tenure and experience, percentage of traveling staff, rural vs urban, complexity and health of the residents, age of the facility, reimbursement rate, turnover rate, leadership and governance. “It is not fair to assume that setting minimum staffing levels will contribute to higher quality” according to Hatting. A staffing mandate will not create new workers, especially if there is no funding tied to the standard.
South Dakota has already experienced nursing home closures this year. Many facilities are limiting admission due to lack of staffing, and the intense scrutiny and regulatory burden of state survey and federal fines is contributing to staff burnout and financial distress. Every provider in the long-term care industry will tell you, even prior to the pandemic, that staffing is their #1 issue. Qualified applicants are no longer seeking a job in healthcare. Today, 57% of facilities are filling vacant position with expensive traveling staff and 42% of nursing homes are limiting admission due to staffing. Rural areas will be disproportionately affected by mandatory staffing levels creating more disparity and lack of access to care for seniors.
Every member of SDAHO, across the continuum of care, continues to work together to contain the spread of COVID-19 and ensure positive outcomes for our most vulnerable residents in South Dakota. As partners in care, we are committed to providing safe and effective high-quality care for our communities and will continue to work collaboratively with state and federal agencies to build up our healthcare workforce.