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  • Krone Weidler

Navigating CMS’s New Staffing Standards: A Guide for Nursing Home Leaders



The Centers for Medicare & Medicaid Services (CMS) recently finalized new minimum staffing standards for nursing homes, effective April 22, 2024. These standards aim to enhance the quality of care but have sparked a significant debate among nursing home leaders, particularly regarding the role of licensed practical nurses (LPNs).


Overview of the New CMS Rule

The new mandate establishes comprehensive minimum nurse staffing requirements, which include:

  • Total nurse staffing standard of 3.48 Hours Per Resident Day (HPRD): This includes at least 0.55 HPRD of registered nurse (RN) care and 2.45 HPRD of direct nurse aide care.

  • Flexibility in Staffing: The additional 0.48 HPRD can be met by any combination of nurse staff, including RNs, LPNs, or nurse aides.

  • 24/7 RN Presence: The rule mandates that an RN must be onsite 24 hours a day, seven days a week, to ensure the availability of skilled nursing care.


Flexibility and Concerns

While the final rule offers some flexibility by including LPN hours in the total nurse staffing, it has raised concerns about its feasibility and impact on resident care. LeadingAge and other industry associations had advocated for the CMS to allow a broader definition of “licensed nurse” to include LPNs more comprehensively.


Implementation and Exemptions

CMS has provided a staggered implementation timeframe and potential exemptions for facilities facing significant workforce challenges, particularly in rural areas. The agency will monitor the implementation closely to determine if any adjustments are necessary. Despite these measures, there is apprehension about the practicality of meeting these standards amidst a widespread workforce shortage.


The Role of LPNs in Long-Term Care

LPNs play a crucial role in long-term care, providing hands-on, clinical care in collaboration with RNs and nurse aides. They are employed at higher rates than RNs in many nursing homes and are integral to the day-to-day operations of these facilities. However, the new rule’s focus on RNs and certified nursing assistants (CNAs) has been perceived as marginalizing the contributions of LPNs.


Challenges for Rural and Local Facilities

Facilities in rural areas, where the LPN workforce is particularly robust, may face significant challenges in meeting the new requirements. The mandate for a 24/7 RN presence is especially daunting for these facilities, which may already struggle with staffing shortages. There is concern that some organizations may shift their hiring focus solely to RNs, further exacerbating the workforce shortage.


Moving Forward

As the new CMS staffing standards take effect, nursing home leaders must navigate these changes carefully. It is essential to recognize the vital role of LPNs in the long-term care workforce and advocate for their inclusion in staffing calculations. By working collaboratively with industry associations and policymakers, facilities can strive to meet the new standards while continuing to provide high-quality care for residents.

At Cadre Healthcare Advisors, we are committed to supporting nursing home leaders through these regulatory changes. Our team of experts is here to help you understand and implement the new CMS staffing standards effectively. Contact us today for more information and personalized assistance.


Krone Weidler, Founder & Principal

Cadre Healthcare Realty Advisors

1095 SE 177th Place, Suite 404-M14

Summerfield, FL 34491

C: (813) 842-2365

O: (866) 355-3594

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