Senior Vice President, Public Policy Analysis and Development
American Hospital Association
September 1, 2023
The AHA strongly believes that a skilled, caring workforce is integral to delivery of high quality, safe care. At the same time, safe staffing is about much more than a number. It is a highly dynamic process requiring flexibility and clinical judgment that accounts for patient needs, facility characteristics and the experience and expertise of the care team. We are concerned that in proposing a one-size-fits-all numerical staffing threshold, CMS would remove the role of clinical judgment in staffing facilities, and inadvertently create patient access challenges across the health care system.
Implementing a numerical staffing threshold could drive nursing homes to further reduce capacity or close in order to meet the requirements. Fewer nursing home beds could adversely impact hospital patients who are denied the specialized care they are prescribed when they must stay, sometimes months, in hospital beds awaiting discharge to post-acute care settings. This could become especially dire in rural and underserved communities. The AHA has already documented rising lengths of stay for hospital patients in need of skilled post-acute care.
The number of workers employed by nursing homes and other senior care facilities remain significantly below pre-pandemic levels largely due to challenges in finding skilled workers. We commend the Administration’s plans to invest in education for health care staff, but training takes time. We are concerned that implementing a numerical staffing threshold in two short years will not resolve the structural health care workforce shortages that have been building for more than a decade.
The AHA looks forward to working with CMS to advance solutions to bolster the health care workforce and deliver high-quality, safe care across the health care continuum.