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ACTION NEEDED: Contact CMS on Minimum Staffing Requirements

NYSHFA|NYSCAL needs a massive response from our members in helping AHCA/NCAL to generate 10,000 unique comments to CMS about how the proposed minimum staffing rule is ill-advised.

Your comments count.

If this proposed rule is adopted as written, it will affect your facility directly. New York State skilled nursing facilities will be required to comply with a federal staffing mandate despite the state mandate already in effect.

However, this proposal is not feasible for two major reasons – the staff does not currently exist nor does the funding. This proposal is completely unfunded with CMS projecting a cost of $4 billion annually. Under this circumstance, the average cost to a facility would be approximately $300,000. In a third-party analysis conducted by Clifton Larsen Allen, the projected cost was predicted to be closer to $6 billion annually.

Let CMS know they made a mistake.

This is a multi-pronged comment campaign. Contact CMS to weigh in on their proposal, using your own circumstance and examples to tell your story. Be sure to:

  • Explain who you are
  • Explain your commitment to quality and the residents you serve
  • Explain that the workforce is nonexistent
  • Make some “ask” 

Use this NYSHFA | NYSCAL tool to help you with your unique comment and tell CMS that this “one-size-fits-all” approach is ill-advised as currently proposed. Follow the simple step-by-step instructions to submit your unique personalized comment by November 6 here. Anyone can comment so encourage your frontline staff and others within your facilities to do the same. CMS is required to read all comments submitted.

NYSHFA | NYSCAL CONTACTS:

Kristin DeVries, MA, MPP
Director of Government Relations
518-462-4800 x.14

Lisa Volk, RN, BPS, LNHA
Director of Clinical & Quality Services
518-462-4800 x.15