Unfunded Minimum Staffing Requirement for Skilled Nursing Facilities (SNFs) 

On September 6, CMS released the proposed rule, Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting (CMS-2023-0144-0001). 

Use the gray box on this page to compose your message to CMS with the following guidelines: 

In the subject line: 

• Please copy and paste the following statement: Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting (CMS-3442-P), so that the comment will be properly considered.

 Addressing the letter:

•  Dear Administrator Brooks-LaSure:

 In the message body: 

• The more personalized you can make your comment, the better. Use your own circumstances and your own examples to drive home your message. Keep the focus on the beneficiaries: your patients and residents.

Outline for Your Comments

 Explain Who You Are

1.  What you do and how long you have been in this line of work
2.  Why you work in long term care
3.  Describe your building: Location, Number of units, Profile of your residents
4.  Assoc. Business Members: Describe your company, where you're located, what service you provide to skilled nursing facilities

Tell Them About Your Commitment to Quality

1. Mention any AHCA Quality Award or other award you have received
2. Explain what your residents mean to you and your team
3. Assoc. Business Members: Describe your observations on commitment to quality in skilled nursing facilities

Our Asks

1. Tell them not to do it.
2. Tell them if they are going to do it, not to do this until the workforce returns
   1. Explain how hard is to get workers and your challenges to get them
   2. Give any story or example of not being able to get staff
3. Tell them it must be funded
4. Tell them it needs to be phased in over 5 years for both urban and rural 
5. Tell them to count LPNs
6. Tell them to count other workers (activities directors, social workers, etc. in the nurse aide category)
7. Assoc. Business Members: Talk about what you've observed regarding workforce challenges of your customers. State any efforts you've seen your customers go through to get workers

This can be done with a few paragraphs unless you wish to provide more detailed examples. 

Please note that there is a 5,000 character limit for all letters. If you have a longer letter, then you can send to CMS, via US Mail, at the following address: 

Centers for Medicare & Medicaid Services,

Department of Health and Human Services,

Attention: CMS-3442-P

P.O. Box 8016, Baltimore, MD 21244-8016

You can also comment directly on the Regulations website http://www.regulations.gov, copy and paste CMS-2023-0144-0001 into the search bar.

If you submit your letter directly to CMS via the Regulations website or by mail, please let AHCA know by email GR@AHCA.org, so we can track how many comments have been submitted.

DEADLINE FOR COMMENTS IS NOVEMBER 6.

CLICK HERE TO VIEW THE MINIMUM STAFFING ISSUE BRIEF

Thank you for taking the time to send a letter to CMS!

-AHCA Grassroots Team