Q: If we meet state-level staffing minimums, will we have sufficient staff under F725, Sufficient Nursing Staff?

A: Meeting state minimums does not guarantee compliance with federal staffing standards.

Federal regulations require facilities to “have sufficient nursing staff with the appropriate competencies and skills sets to provide nursing and related services to assure resident safety and attain or maintain the highest practicable physical, mental and psychosocial well-being of each resident, as determined by resident assessments and individual plans of care and considering the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment.”

States with minimums require a specific number of staff, while the federal rule is more dynamic; more nursing staff may be necessary to meet federal mandates.

Each surveyor will observe and interview to consider nurse staffing; if they find issues, surveyors then investigate further. These investigations may uncover resident care or safety issues linked to insufficient nurse staffing.

Providers can use the CMS staffing analysis form to evaluate sufficiency of nurse staffing. Self-assessing can help determine if residents and staff feel enough staff are present. Similarly, the form asks if the facility used the facility assessment, containing resident census and acuity, to determine needs.

Make sure this data guides staffing decisions. State surveyors also use the Payroll Based Journal system to examine staffing, so ensure PBJ data is submitted timely and accurately. By using these surveyor tools as a resource, facilities can ensure they meet staffing mandates at both the state and federal levels.

Amy Stewart, MSN, RN, RAC-MT, RAC-MTA, DNS-MT, QCP-MT, is vice president of education and certification
strategy for AAPACN
. Send her your nursing-related questions at [email protected]