Court Decision Halts Biden-Era Mandate

Joe Biden

A federal judge struck down the Biden administration’s nursing home staffing mandate, ruling the government overstepped its authority by imposing staffing requirements without considering individual resident needs.

Key Takeaways

  • US District Judge Matthew Kacsmaryk ruled that CMS exceeded its authority by replacing Congressional staffing standards with its own requirements.
  • The overturned rule would have required nursing homes to have registered nurses on-site 24/7 and mandated at least 3.48 nurse staffing hours per resident day.
  • Nursing home industry groups argued the rule threatened facility closures and would displace seniors due to staffing shortages and financial burdens.
  • Patient advocates expressed disappointment, arguing the standards would have improved care quality for vulnerable nursing home residents.
  • The ruling underscores tensions between standardized care requirements and personalized approaches based on individual resident needs.

Judge Rejects Federal Nursing Home Staffing Mandate

US District Judge Matthew Kacsmaryk delivered a significant blow to the former administration’s efforts to reform nursing home care standards when he struck down a federal rule that would have required nursing homes to increase staffing levels. The rule, finalized by the Centers for Medicare & Medicaid Services (CMS) in 2024, mandated that nursing homes have registered nurses on-site 24 hours a day, seven days a week, and required at least 3.48 nurse staffing hours per resident day. Judge Kacsmaryk determined that CMS had overstepped its authority by imposing these requirements.

In his ruling, Judge Kacsmaryk concluded that the CMS regulation illegally replaced staffing requirements that were specifically outlined by Congress. The court found that the federal agency had disregarded the statutory requirement to consider the nursing needs of individual residents, instead imposing a one-size-fits-all approach that did not align with Congressional intent. This ruling represents a significant check on regulatory power and emphasizes the limits of administrative agency authority.

Industry Relief vs. Patient Advocate Disappointment

The American Health Care Association (AHCA) and other industry groups had sued to block the regulation, arguing that it would place impossible burdens on nursing homes already struggling with workforce shortages. The court’s summary judgment in favor of these groups was celebrated by industry leaders who had warned about potential widespread closures of nursing facilities if the rule had been implemented. Many facilities, particularly in rural areas, expressed concern about their ability to recruit sufficient staff to meet the mandated requirements.

Patient advocates expressed profound disappointment with the ruling. Organizations like the National Consumer Voice for Quality Long-Term Care argued that the staffing requirements were necessary to ensure proper care for vulnerable residents. They pointed to research suggesting that higher staffing levels correlate with better health outcomes and fewer instances of neglect in nursing facilities. The ruling leaves in place the existing system, which advocates argue has allowed understaffing to persist in many facilities across the country.

Legal Reasoning Behind the Decision

At the heart of Judge Kacsmaryk’s ruling was the determination that CMS had exceeded its statutory authority. The judge specifically cited language from existing law requiring that nursing homes provide services to attain the highest practicable well-being of each resident. This language, the court concluded, indicates Congress’s intent that staffing requirements should be tailored to the specific needs of residents rather than imposed as universal standards regardless of individual circumstances.

The court also criticized the rule for setting baseline staffing requirements that did not adequately account for variations in resident needs across different facilities. Judge Kacsmaryk determined that by mandating specific staffing ratios, CMS had effectively substituted its judgment for the more nuanced approach envisioned by Congress. This substitution, according to the court, represented an unauthorized expansion of regulatory authority that required correction through judicial intervention.

Implications for Future Nursing Home Regulations

This ruling has significant implications for the future of nursing home regulation. It suggests that efforts to impose nationwide standards may face heightened judicial scrutiny, particularly when they appear to contradict or expand upon Congressional directives. Industry leaders, including Katie Smith Sloan of LeadingAge, have suggested that rather than imposing staffing mandates, federal efforts should focus on addressing funding gaps and workforce development challenges that make it difficult for facilities to maintain adequate staffing levels.

The Centers for Medicare & Medicaid Services has not yet indicated whether it will appeal the ruling. The decision leaves in place the existing regulatory framework, which requires nursing homes to provide sufficient staffing without specifying numerical requirements. For the foreseeable future, nursing homes will continue operating under these more flexible standards, with state-level regulations providing additional oversight in many jurisdictions. The ruling underscores the ongoing tension between standardized requirements and personalized care approaches in the nursing home industry.

Sources:

  1. Federal Judge Strikes Down Biden-Era Rule That Required Nursing Homes to Increase Staffing
  2. Judge rules against Biden rule to up nursing home staff
  3. Judge rejects Biden mandate for nursing homes to bolster staffing