NETWORK Lobby for Catholic Social Justice Public Comment on HHS’s Center for Medicare & Medicaid Services’ Proposed Rule Regarding Minimum Standards for Nursing Home Staffing
October 26, 2023
NETWORK Lobby for Catholic Social Justice believes that all people have inherent dignity and the right to basic life essentials. Guided by the essential principles of Catholic social justice, NETWORK is committed to advancing federal policy that protects our nation’s most vulnerable communities. We submit strong support for the U.S. Department of Health & Human Services’ Center for Medicare & Medicaid Services’ proposed rule regarding Minimum Standards for Nursing Home Staffing.
In voicing our support for strong minimum staffing standards for U.S. nursing facilities, we honor that commitment in two fundamental ways. First, nursing home residents are plainly among the most vulnerable of all populations in the U.S. Those who require nursing home services are inherently unable to care for themselves; they are elderly, disabled, seriously ill, or on a difficult path to rehabilitation—and all need 24-hour residential care.
Moreover, our nation must do better for the low-wage workers who provide the basic services that we all depend on for both our well-being and a strong economy, and who overwhelmingly bear the burdens of caring for nursing home residents. No one can deny that they deserve standards that enable them to shoulder those responsibilities under reasonable and humane working conditions.
The nursing home industry receives nearly $100 billion each year in taxpayer-funded Medicare and Medicaid payments. And yet, all too many nursing home residents live in poor and even unsanitary conditions, unable to have some of their most basic needs met by overworked, struggling staff. As numerous studies have shown, the root of these neglectful conditions is widespread understaffing. Strong correlations exist between nursing home staff levels and quality of care, rates of death from COVID-19, findings of abuse and neglect, and failed health inspections.
The lack of strong, science-based standards does not just leave nursing home residents more vulnerable to poor conditions and worse health outcomes. It also threatens the safety and wellbeing of nursing facility workers, creating a harmful cycle of understaffing. The damaging mix of worker injuries and exhaustion, low wages, and resulting burnout from unacceptable workload demands creates and exacerbates chronic understaffing in facilities with deficient staffing levels.
For these reasons, NETWORK strongly supports the rule recently proposed by the Centers for Medicare & Medicaid Services (CMS) to set minimum nursing home staffing levels. The rule’s requirement of a constant Registered Nurse on-site presence, and its minimum requirements for nursing and other care staff based on the actual needs of the facility’s residents, sets a necessary, basic federal staffing floor.
Our shared commitment to human dignity and respect for vulnerable nursing home residents and workers demands nothing less. Thus, NETWORK urges the adoption of CMS’s proposed rule on minimum standards for nursing home staffing. Thank you for the opportunity to comment on this important initiative.