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Insights and Trends

CMS to Change SNF Staffing Mandate: How Your Hospital May be Impacted

Key takeaways:

Impact of staffing mandate for SNFs

Following a year-long study, CMS is on the verge of proposing new mandatory staffing levels at skilled nursing facilities (SNFs). This is projected to improve care quality but could cost the industry over $10 billion to maintain according to a CliftonLarsonAllen (CLA) report.1,2 This comes after years of inadequate patient outcomes put forth by SNFs – due in part to a lack of highly trained staff.

In 2001, CMS released a report recommending SNF staff spend 4.1 hours with each patient each day.3 However, the inability to grow SNF staffing numbers has continued to hinder many facilities from achieving this ratio. Additionally, research highlights that SNF staffing won’t return to pre-pandemic levels until 20274 – placing more strain to an already struggling industry.

The current state of staffing mandates for SNFs:

    • 94% of SNFs today do not meet the 4.1 hours per patient day (HPPD).
    • Only 27% current meet the 3.2 HPPD.

Due to these numbers, the CMS staffing mandate is expected to hit below the 3.1 HPPD ratio, unless payment rates are increased for SNFs which would result in a higher mandate.

Even if CMS gave me enough money to increase pay for my nursing staff by 50%, I still would not be able to meet any kind of added benchmark because those people just do not exist in my market. There's no one out there for me to hire,” notes a SNF leader in a recent Advisory Board report.5

How could the staffing mandate impact your post-acute operations and outcomes? 3 things to consider:2

  1. Reduced hospital throughput and longer length of stay (LOS): As SNF beds become limited, hospitals will face throughput challenges with backlogged emergency departments and longer inpatient LOS without appropriate discharge options. These obstacles will require post-acute sites, such as inpatient rehabilitation, to prepare for increased demand across the care continuum.

  2. Increased financial pressure on patients and providers: Patients who are unable to find a SNF placement due to staffing shortages still require a care setting equipped to take on their needs. As more patient divert from SNFs, other post-acute settings could begin to experience a rise in admission volume – leading to scarce resources, bed capacity and capital to effectively care for this demographic.

  3. Staffing minimums for other care settings. Once a SNF staffing mandate is enforced, the possibility of other sites of care experiencing increased regulation and staffing requirements is a high possibility.

The increased need for inpatient rehabilitation as the SNF staffing mandate nears

Inpatient rehabilitation is uniquely equipped to care for patients often treated by SNFs and help them reach their recovery goals. It is the only post-acute setting that provides daily intensive multi-disciplinary therapy, regular physician oversight and around the clock nursing care. The unique level of care enables complex patient needs to be effectively and efficiently treated.

The specialized care provided within inpatient rehabilitation through an acute rehabilitation unit (ARU) or inpatient rehabilitation facility (IRF) has proven to produce positive long-term outcomes both during and after a patient’s hospital stay.

Additional benefits inpatient rehabilitation offers to acute hospitals include:

  • Increased clinical and quality effectiveness. Inpatient rehabilitation is known for producing exceptional clinical and quality outcomes and reducing hospital readmission rates – benefiting the entire hospital.

  • Streamlined interdisciplinary team approach. Specialized care requires expertise from specialized clinicians, including highly trained medical directors. Having the expertise within the hospital’s care continuum reduces the opportunity for errors while improving care consistency and transitions.

  • Improved patient throughput management. Having inpatient rehabilitation services available within a system’s care continuum helps ensure that patients receive the right form of care at the right time in their care journey. This frees up needed staff and acute bed space and allows patients to effectively make progress in their recovery.

Importance of post-acute partnership

Shifting healthcare regulations will continue to change the way hospitals and health systems approach care delivery and accessibility. Having a contract management or joint venture rehabilitation partner with a strong pulse on industry changes helps hospitals better meet the needs of their patients and community.

The pending SNF staff mandates could pose potential post-acute capacity issues, but partnership can help prepare for what is to come.

With decades of experience navigating the full care continuum, Lifepoint helps its partners expand patient access in their local communities, while also enhancing quality and operational efficiency.

Is your hospital looking to add a new service line or explore a new partnership opportunity? Read our white paper to learn how a hybrid partner approach can play a key role in your hospital’s outcomes.


  1. CliftonLarsonAllen LLP (CLA). (2022, December). Staffing Mandate Analysis In-Depth Analysis on Minimum Nurse Staffing Levels [PowerPoint slides].
  2. A new SNF staffing mandate is coming. Are you ready? (2023, April).
  3. Harrington, C., Dellefield, M. E., Halifax, E., Fleming, M. L., & Bakerjian, D. (2020, June 29). Appropriate nurse staffing levels for U.S. nursing homes. Health services insights.
  4. Stulick, A. (2023, January 19). Data doesn’t lie: Current pace sets nursing home workforce recovery back to 2027. Skilled Nursing News.
  5. Advisory Board. (2023, March). Nursing homes are closing (and you should be paying attention). Radio Advisory.


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