CMS has released an interim final rule that repeals the federal minimum staffing standards for nursing homes. The repeal removes the 24-hour RN requirement and the fixed hours per resident day for RNs and CNAs, returning the industry to the older baseline of one RN onsite for eight consecutive hours per day.

CMS Staffing

The repeal does not reduce regulatory pressure. It shifts the burden to facilities to show that staffing levels are safe, appropriate, and supported by outcomes. Operators who ignore this shift will see increased survey risk in 2026 and beyond.

This update matters for every skilled nursing facility. It should immediately influence how you prepare for survey, how you structure QAPI, and how you complete your Facility Assessment.

What CMS Repealed

CMS officially removed:

• The 24-hour, seven-day RN requirement.
• The 0.55 RN, 2.45 NA, and 3.48 total nursing hours per resident day.
• All definitions tied to HPRD.
• All staffing updates added in the 2024 Minimum Staffing Final Rule.

These standards cannot be enforced until September 30, 2034 due to federal law.

CMS Staffing

What This Means for Nursing Homes

The repeal does not eliminate accountability. Survey teams will continue citing insufficient staffing under existing F-Tags when outcomes signal gaps in care. Facilities should expect:

• Greater focus on the Facility Assessment.
• A deeper review of staffing plans and acuity alignment.
• More citations tied to outcomes such as falls, pressure injuries, elopement, behavioral symptoms, and delayed care.
• Increased use of QAPI to evaluate staffing sufficiency.

Surveyors will expect facilities to justify their staffing decisions with data, not promises.

How Facilities Should Adjust Now

Strengthen Your Facility Assessment

Your assessment must show how staffing meets resident needs. The repeal makes this document more important, not less. Surveyors will ask how your staffing model supports acuity, risk areas, and resident safety.

Reinforce QAPI

QAPI is now the regulatory backbone for staffing oversight. Facilities should track:

• Call light response times
• Missed care trends
• Falls and injuries
• Wounds
• Behavior management
• Critical incidents

CMS expects facilities to prove that QAPI drives staffing decisions.

Complete Internal Mock Surveys

Mock surveys will help facilities identify staffing gaps that may drive citations. SMK Medical’s mock surveys focus on:

• Pathways linked to staffing
• Observation of care delivery
• Real risk identification
• Interview accuracy
• Immediate preparation for surveyor questions

How SMK Medical Supports Facilities Through This Change

Mock Survey Services

Our mock survey process identifies staffing-related compliance gaps across all regulatory pathways. We teach leaders how to defend staffing decisions during survey and reduce exposure across F684, F600, F689, F697, and others.

QAPI Program Development

We build and manage QAPI programs that link staffing, Facility Assessment data, and quality measures. SMK Medical creates systems that surveyors respect and that leadership can actually use.

LTC and Post Acute Care Consulting

We support SNFs nationwide with:

• Survey readiness
• Regulatory compliance
• Facility Assessment development
• Quality Measure improvement
• Leadership coaching
• Risk reduction strategies

SNF Staffing and Compliance Support

We help leaders build defensible staffing plans that match acuity and reduce survey risk.

Bottom Line

The federal ratios are gone for now, but compliance expectations have increased. Facilities must show that staffing is thoughtful, data-driven, and aligned with resident needs. Operators who take a proactive approach will be in a stronger survey position.

SMK Medical is ready to help you prepare.

Call to Action

If your organization needs support with Mock Surveys, QAPI, Facility Assessments, or comprehensive post acute care consulting, schedule a consultation at SMKMed.com or call 313-314-8267.