Template Sign-On Letter for Minimum Staffing Rule for Organizations

On September 6, 2023, the Administration published a notice of proposed rulemaking (NPRM) that would, for the first time, establish a national minimum staffing standard for nursing homes participating in Medicare and Medicaid. There is now a 60-day comment period ending November 6^th in which the public can weigh in on this proposed rule.

This NPRM is an important development in the fight to improve nursing home quality of care and working conditions. Though the proposed regulation needs improvement, it is a paradigm shift in regulating nursing homes to ensure better care. Given the workforce and the discriminatory staffing that occurs in nursing homes, it is also a major step forward in addressing racial and gender inequity.

Consumer groups and unions have developed a template letter for advocates to use to suggest improvements in the proposed rule and to show support for finalizing it. We know that the nursing home industry is pouring millions of dollars into an effort to derail the NPRM. We need to counter that!

The template may be adapted to reflect your organization’s priorities and/or the experience of your members/constituents. Feel free to circulate this template among member and partner organizations.

The template letter was developed by a number of groups, including the National Consumer Voice for Long-Term Care, Justice in Aging, the Center for Medicare Advocacy, the AFL-CIO, the Service Employees International Union, the National Committee to Preserve Social Security and Medicare, California Advocates for Nursing Home Reform, Michigan Elder Justice, the Long-Term Care Community Coalition and others.

Instructions

Comments must be received by November 6^th. To file comments, download the template language, add your organizational or personal perspective and save the document. Please make sure you choose one of two alternative recommendations for licensed nurse staffing that are bracketed on the top of page 3 (instructions for this part are also found in endnote xi).

Comments may be filed electronically by going to this federal regulatory website and clicking on the “Comment” button on the left side, near the top.

Comments can also be filed by mailing in a hard copy via the U.S. Postal Service to the following address:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–3442–P, Mail Stop C4–26–05
7500 Security Boulevard
Baltimore, MD 21244–1850

Make sure hard copy comments are postmarked by October 31st in order to be sure that they arrive in time. We strongly recommend overnight delivery.

Thank you for your help in this effort to improve nursing home care and working conditions.

If you have any questions, please contact Sam Brooks at sbrooks@theconsumervoice.org.