Memo

To: All County Board Members, DPCC Board Members, Family Members, Staff and Volunteers
From: Janelle Chadwick, Administrator
Date: November 1, 2023
Re: Will You Help Us Tell CMS Why Staffing Mandates Won’t Work?

As you may be aware, the DuPage Care Center has received a FIVE STAR rating for Staffing based on required staffing parameters for the State of Illinois. Now, the Centers for Medicare & Medicaid Services (CMS) have proposed federal minimum staffing standards. The CMS staffing mandate will not allow us to count imperative members of our care team. This mandate will negatively impact our reimbursement. This mandate may require changes in our care delivery model and may impact our ability to admit residents that require our help. We need your help! Please review the message below and take the necessary actions to support the DuPage Care Center!
The Centers for Medicare & Medicaid Services (CMS) proposed minimum staffing standards for nursing homes that would have a real impact on all of us at DuPage Care Center. Sadly, the nurses and aides needed to meet these requirements simply do not exist and nursing homes do not receive adequate funding to be able to hire the ones that are out there.
If this rule is finalized, it could mean any of the following for nursing homes and the people we serve:

• Decreased access to care: Some providers would have to take beds offline or close entire units due to insufficient staffing, which means serving fewer older adults in need of care.
• Longer shifts for staff: RNs and nurse aides could have to work longer shifts to meet HPRD and 24/7 RN requirements.
• Less money for other types of staff: The nursing home would be forced to retain fewer LPNs and other staff who contribute to the quality of life to have enough money to hire the required numbers of RNs and nurse aides.
• Increased costs for residents: Nursing homes that accept private pay residents would have to increase resident costs to cover the costs of hiring new RNs and nurse aides.

As a critical member of our family, you can help ensure our organization isn’t forced to deal with these negative implications.

Here are three easy steps that anyone can take to tell CMS to delay the proposed rule.

Step 1: Go to the LeadingAge Action Alert.

Step 2: Complete the form using this language then click “send!”
SUBJECT: Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting (CMS-3442-P)
My name is [insert name] and I am a [Board Member/Family Member/Staff Member/Volunteer] at the DuPage Care Center. I am concerned about the proposed minimum staffing standards. There are not enough RNs and nurse aides to hire and nursing homes don’t receive enough funding to pay for additional staff.
If this rule is finalized, then this could lead to decreased access to care, longer shifts for staff, less money for other types of staff, increased costs for residents. CMS, delay this rule until there are enough qualified applicants and adequate funding to address staffing levels realistically throughout the long-term care continuum.

-or insert your own story about why nursing homes are important to you.


Step 3: Encourage your fellow board members, family members, staff member and/or volunteers to submit comments by November 6.

*****To offer some clarification, the proposed CMS Staffing Mandate is very complex. The information you received was a modification to the LeadingAge National letter. This was done in an attempt to clarify the impact as it relates to DPCC in the state of Illinois. Our primary message is this:
Based on Illinois Staffing requirements, DPCC is a 5 Star for Staffing based on our submission of payroll. This is excellent. However, the proposed federal CMS Staffing Mandates, do not count key staff that deliver direct care and the minimum staffing requirements are higher. Based on the proposed CMS Staffing Mandates, DPCC would fall short. If these proposed CMS Staffing mandates are passed, the majority of facilities in the United States would not meet the requirements. The cost to achieve the requirements would be so high that most facilities would not be able to continue to operate or would need to cut non-direct care delivery staff to move those dollars to attract more RN’s and CNA’s with higher wages. Keep in mind, the additional RN’s and CNA’s are not there. Facilities would need to try to take from other facilities, hospitals, hospices, etc.
Advocacy is occurring in Washington D.C right now. There are many Senators that agree with our position. We are working to strengthen our voice. We fully understand this is a complex message. To respond to questions, you need to first understand that we are not short-staffed. Yes, we use agency, but we are staffed at a 5 STAR level for Illinois. We would prefer consistent staff without the use of agency, but the workforce is very limited. Also note, our turnover rate is very low compared to other nursing homes in our state and region of the United States.