Several of the nation’s largest aging services and nursing organizations have united to defend Licensed Practical Nurses and criticize a proposed Centers for Medicare & Medicaid Services nursing home staffing rule.

The groups called the conspicuous absence of LPNs from proposed hourly requirements “yet another example of [the mandate’s] fundamental flaws,” and called on CMS rescind the proposed mandate entirely. LPNs make up 13% of the nursing home workforce and complete a large majority of post-acute care work in those facilities, the authors said.

“We are requesting the Administration to withdraw this archaic, unfunded health care policy and instead focus on meaningful, supportive ways to grow and retain the nursing home workforce,” the American Health Care Association, LeadingAge and the National Association of Licensed Practical Nurses and six other organizations wrote in their Oct. 27 comment letter.

It came in a wave of nearly 47,000 messages that flooded CMS during a two-month public comment period. 

LPNs in the spotlight

The joint statement argued that omitting LPNs from the staffing mandate would have a large impact, felt throughout the long-term care industry.

“As currently proposed, this blanket mandate not only sends the message that LPNs are not as important as other licensed nurses, but it also discourages certified nursing assistants (CNAs) who are looking for more care advancement opportunities,” they wrote.

Some nursing homes have said they would be forced to eliminate LPN positions to hire more and more costly Registered Nurses to meet rigid regulations. Others have predicted the overall rule could displace up to 300,000 residents. 

With such potential consequences in mind, the joint comment calls for CMS to reevaluate its stance on LPNs and properly acknowledge them as vital members of the long-term care sector. 

“LPNs should be recognized and regarded with RNs as nurses — that’s what they are,” the letter says. “This means any RN requirement should include all worked hours of LPNs in it, as both are licensed nurses. These are integral and valued members of our nursing homes, and they should be treated as such.”

Mandate complexities continue to frustrate

While these organizations oppose the implementation of the mandate in general, even pro-mandate organizations and elected officials have weighed in with concerns about the LPN issue.

Letters from US Representatives and Senators earlier this month both urged CMS to make its proposed staffing requirements even stronger by adding LPNs to the mandate.

In contrast, however, the joint comment from AHCA, LeadingAge and nursing groups described the proposal’s omission of LPNs as evidence that the whole proposal is untenable. 

“If CMS finalizes the mandate, it calls into question how ignoring hundreds of thousands of care professionals that contribute to resident care would somehow accomplish the rule’s intended goal,” AHCA said in a related statement Monday.