Staffing Mandate Analysis

​​​​​​Commissioned by AHCA/NCAL, professional services firm CLA (CliftonLarsonAllen LLP) analyzed the impact of President Biden’s proposed rule to establish federal staffing minimums on nursing homes. The proposed rule would require specific nursing home staff to spend a minimum number of hours with each resident – 2.45 nurse aide hours per resident per day (HPRD) and 0.55 registered nurse (RN) HPRD – as well as have a RN on site 24 hours a day. 

Utilizing Payroll-Based Journal (PBJ) data and hourly rates from Medicare cost reports, CLA estimated the additional staff necessary to meet the staffing requirement, as well as the costs associated with the additional staff.  Among CLA’s findings:

  • Nursing homes would need to hire an estimated 102,154 additional full-time employees (80,077 nurse aides and 22,077 RNs).
  • The proposed mandate would cost nursing homes approximately $6.8 billion per year – higher than the $4 billion per year estimate from the Centers for Medicare and Medicaid Services (CMS).
  • 94 percent of nursing homes are currently not meeting at least one of the three proposed staffing requirements: the 2.45 nurse aide HPRD, the 0.55 RN HPRD, and the 24/7 RN. 
  • Of the 94 percent, 36 percent of facilities are not meeting all three requirements; 34 percent are not meeting two of the requirements; and 24 percent are not meeting one of the requirements.
  • Nursing  homes that did not meet at least one of the requirements were more likely to have a majority of their residents relying on Medicaid (56 percent average Medicaid census) compared to facilities that met the criteria (43 percent). 
  • If nursing homes are unable to increase their workforce to meet these new requirements, more than 280,000 nursing home residents or nearly one-quarter of all residents, could be impacted by census reductions.
The overall workforce and financial impact of the staffing mandate varies by state. See the impact on each state in the interactive report below.

 Read the National Report

The SNF industry would need to hire approximately 102,000 additional full-time equivalents at an estimated annual cost of $6.8 billion.

 State-Level Impact