Monday, November 6 marked the end of the formal public comment period for CMS’s nursing home minimum staffing rule draft. WHCA/WiCAL has provided recent updates to members. Most recently:

• One Thousand Strong: Wisconsin Providers and Stakeholders Generate More than 1,000 Public Comments on CMS’s Staffing Mandate Proposal
• Read WHCA/WiCAL’s Public Comment Submission on CMS Minimum Staffing Proposal

Importantly, while the comment period has ended, WHCA/WiCAL’s and AHCA/NCAL’s work is not done. WHCA/WiCAL will also continue Congressional advocacy on the CMS proposal. WHCA/WiCAL has worked with members of both parties to share provider concerns about the draft, and plans additional outreach and meetings with targeted members of Congress.

On the Congressional front, several members of Congress have also been advocating for or against the proposed rule with letters to CMS. Below are the Congressional letters that have been sent to CMS:

• US Senate
  • Sen. letter opposed to the rule, sharing provider concerns
  • Senate letter in favor of the CMS rule, with additional requests for workforce-related flexibilities.

*Note: neither of Wisconsin’s two US Senators signed on to either letter.

• House
  • Congressional letter opposed to the rule, sharing provider concerns
    • Rep. Bryan Steil (R-WI-01) signed on to this letter.
      • See WHCA/WiCAL article
  • Congressional letter in favor of the CMS minimum staffing, requesting an increase to nursing hours per patient day (HPRD) by 40% compared to the current CMS proposal.

See also a joint opposition letter penned by AHCA and the National Association of Licensed Practical Nurses (among other groups) here.

Please direct any questions or comments to WHCA/WiCAL VP of Government Relations and Regulatory Affairs, Jim Stoa.