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SUBMIT A COMMENT ON THE PROPOSED NURSING HOME STAFFING REGULATIONS!
During his State of the Union speech, President Biden promised to improve the quality of long-term care in nursing homes with new federal minimum staffing requirements, increased oversight and enforcement, and expanded workforce initiatives to recruit and retain staff.
You can comment in the form below or go to the Federal Register Comment Form linked below.
We have included some sample language at the end of this post.
Unbelievably, there currently is no standard so nursing home operators can do what they want. And, generally, that’s not good.
HHS recently proposed new regulations to create a federal floor for staffing levels, so that nursing home owners could not slash staffing to unsafe levels. The proposal would require every facility to have a Registered Nurse on site 24/7, to have a certain minimum number of registered nurses and nurse aides to help provide routine care, and to staff according to resident needs based on a robust assessment of the facility’s residents. If finalized, these standards would go into effect in phases.
The nursing home industry receives nearly $100 billion annually from American taxpayers, yet too many nursing homes chronically provide poor or substandard care that endangers residents, diminishes quality of life and puts both staff and patients at risk. These challenges were particularly exposed during the COVID pandemic when over 200,000 nursing home residents and workers died—around one-fifth of all COVID-19 deaths in the United States.
Click on Federal Register Comment Form to go through the HHS website.
IF you choose to submit through the Government form we would love for you to copy and paste your comment and send it to: ICAN@IowaCAN.org
My name is [Insert Name]. I am a [nursing home resident, direct care worker, doctor, nurse, family member of someone who lives in a nursing home, healthcare advocate, etc.] in [city/town, state] who very much supports improved staffing and safety in long-term care nursing homes.
The Biden Administration’s proposed rule to create a federal minimum standard for staffing that ensures all patients get more of the care they need is long overdue and incredibly modest. Many residents will need more care than can be accommodated under the standard, which is why it’s important to start with this floor and create the opportunity to build on the standard over time.
In fact, (insert more customized detail here)
Sample from family caregiver:
[In fact, as someone with direct experience caring for an aging person with Parkinson’s Disease, I know from experience that an individual with PD symptoms will often require far more attention than would be required under the proposed minimums. For many people who have degenerative or progressive diseases, the demand for services will only increase as the person ages and the disease worsens.
In my household, I currently take care of my aging mother who has mobility problems, rheumatoid arthritis, dementia and Parkinson’s psychosis with help from an in-home care agency. But as my mother ages and potentially develops other symptoms that reduce her mobility further or endanger her, she may need to be in a facility where she gets 24-hour supervision that I cannot provide at home. . . .]
Sample from health care advocate:
Aging people are the fastest growing segment of the population, particularly those over 80 who are likely to need the most support. With the population of people 65 and older expected to almost double by 2060, now is the time to start planning for their healthcare needs. While most of these people will continue aging at home, millions will require institutional care in a residential facility because of health conditions that cannot be managed at home, because they have no family support nearby or for other reasons.
While it’s a challenge to find caregivers and nurses to undertake this work, it’s possible to attract and to retain staff to provide services if nursing home operators and regulators prioritize compensating workers properly. Providing care to elderly people and people with disabilities requires patience and skill. The risk of injury is high, the hours are inconvenient and many workers in the care profession don’t even get access to healthcare insurance for themselves and their families. Nurses, direct care workers, techs, and other health professionals have the highest rates of non-fatal injuries across sectors and, as we learned during COVID, are exposed to some of the worst health hazards as part of their job. Good compensation and affordable health coverage are the very least they should expect.
Yet despite the skills, dangers and growing demand, direct care workers are among the lowest paid workers in the nation. Just like in any profession, improving wages, working conditions and respect on the job are the main ways to attract and recruit caregivers and nursing staff and to build a sustainable workforce in a sector that will continue to expand for the foreseeable future. Improved pay and working conditions also saves employers money in the long run because it reduces turnover, staff training expenses, and better productivity on the job.
Sample from Direct Care Worker:
Just like in every other profession, care for people in nursing facilities depends heavily on the training, skills and commitment of the workers who provide the care. I am a [describe job and place where you work] and I provide care to X number of people who have a range of disabilities, conditions and needs.
Although I enjoy this work and have strong relationships with my residents, the pay is very low and forces me to take on additional jobs to make ends meet. For instance, [include details]. Not only is the pay low, but although we are providing health services to aging people, the health coverage available for us as workers is very poor. The coverage is [describe].
The lack of health coverage and adequate pay puts direct care workers are not sufficient to compensate workers for the amount of risk we face everyday in caring for people with all kinds of communicable disease. Direct care workers are at high risk of injuring themselves with lifting, carrying and moving many residents with mobility issues. They also face tremendous stress dealing with dementia, hallucinations, delusions, memory loss, depression and other common conditions in our patients that we are often powerless to treat.
Constant short staffing adds more stress to both workers and to patients. Direct care workers can only respond to a fixed number of patients and each patient has different needs. For patients to receive even basic care like toileting, washing, exercising and feeding there must be enough staff to give individualized attention. To improve quality of life so that residents get some actual interaction that will support cognitive and emotional health requires even more. The kind of care we can provide each patient is directly tied to the number of staff.
Doing direct care work requires tremendous physical and mental stamina and should be compensated fairly for the good of workers and for the best care of our patients. Until nursing homes pay people fairly and recognize this work as skilled labor, they will not attract more people to the field or retain enough people to improve the quality of care and that means nursing home residents will suffer.
That’s why I very much support this first step from the Biden Administration in establishing a floor for staffing as a first step towards improving the standards for workers and for patients. I encourage HHS and CMS to finalize these rules as soon as possible and to start improving on them even as they start to implement the new standards.