Continuous Skilled Nursing Quality Improvement Act of 2025
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.