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S 1920119th CongressIntroduced

Continuous Skilled Nursing Quality Improvement Act of 2025

Introduced: May 22, 2025
HealthcareSocial Services
Standard Summary
Comprehensive overview in 1-2 paragraphs

The Continuous Skilled Nursing Quality Improvement Act of 2025 would reframe Medicaid-funded private duty nursing as “continuous skilled nursing services,” require licensing standards for these services, and develop national quality standards. It directs the Secretary of Health and Human Services to convene a broad working group to establish national quality standards, publish them for use by states and providers, and ensure that these services are integrated into home- and community-based (HCBS) waivers and quality measure sets. The bill also clarifies that providers of these Medicaid services are not bound by the Medicare home health Conditions of Participation rules, and requires regular updates to related waiver definitions and quality measures. Overall, the legislation aims to raise consistency and quality in Medicaid continuous nursing services across states, with ongoing stakeholder input and periodic updates.

Key Points

  • 1Redefinition and licensure requirement:
  • 2- Replaces the Medicaid term “private duty nursing services” with “continuous skilled nursing services,” effective 18 months after enactment.
  • 3- Requires that complex-care patients receive these services from a licensed nurse (RN or LPN) when a State determines multiple hours of daily continuous nursing are needed.
  • 4National quality standards:
  • 5- Within 180 days, the Secretary must form a working group drawn from providers, beneficiaries, advocacy groups, State Medicaid officials, accrediting bodies, and other stakeholders to develop national quality standards for Medicaid continuous skilled nursing services.
  • 6- Not later than 1 year after the working group’s first meeting, the Secretary must publish the national standards for use by State Medicaid programs, managed care entities, and providers, after a public notice and comment period.
  • 7Clarification on participation requirements:
  • 8- The Secretary will issue a letter to State Medicaid Directors clarifying that providers of Medicaid private duty (now continuous skilled) nursing services are not required to meet the Conditions of Participation for CMS-certified home health agencies under Medicare.
  • 9Integration with HCBS waivers and measures:
  • 10- Within 18 months, add continuous skilled nursing services to the list of HCBS waiver services, aligning them with the revised definition.
  • 11- Within 1 year, update the HCBS Quality Measure Set to include core and supplemental quality measures for these services, with at least an every-8-years formal review and public participation.

Impact Areas

Primary affected groups/areas- Medicaid beneficiaries, including full-benefit dual eligibles, who require long or complex skilled nursing care through Medicaid.- Private duty nursing agencies and the workforce (nurses, including RNs and LPNs) delivering Medicaid-funded continuous skilled nursing services.- State Medicaid programs and managed care entities contracting for HCBS and private duty nursing services.Secondary and broader effects- Accrediting bodies and private duty nursing associations involved in setting professional standards.- HCBS waiver programs and the Home and Community-Based Services Quality Measure Set, which will now include measures for continuous skilled nursing services.- Patient advocacy groups and policymakers focused on care quality, patient safety, and access to continuous skilled nursing care.Additional considerations- Regulatory and implementation shifts as CFR definitions are revised and new national standards are created; potential realignment away from certain Medicare home health COP requirements for this Medicaid-specific service.- Ongoing need for public comment, periodic updates (not less than every 8 years for measures), and intergovernmental coordination across federal and state levels.
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