CHICAGO – Attorney General Kwame Raoul, as part of a coalition of 18 attorneys general, filed a comment letter opposing a federal proposal to eliminate minimum staffing standards and other comprehensive regulations for long-term health care facilities.
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“These standards increase access to long-term care, protect vulnerable patients, improve care and help to prevent fraud,” Raoul said. “I urge this administration to ensure that minimum staffing requirements are in place, and I will continue to stand up for seniors who need care in Illinois and across the country.”
The Nursing Home Reform initiative was instituted by the Biden administration in May 2024 at the suggestion of the Centers for Medicare & Medicaid Services at the Department of Health and Human Services. The initiative was designed to create national requirements for a minimum number of nursing hours in skilled nursing facilities, including minimum staffing requirements for medical professionals like registered nurses, and a requirement that every facility have registered nurses to provide care on-site at all times.
The U.S. Department of Health and Human Services and the Centers for Medicare and Medicaid Services (CMS) recently proposed an interim final rule that repeals key components of the May 2024 Minimum Staffing Standards for Long-Term Care Facilities Final Rule.
In their letter, Raoul and the attorneys general note studies show that the increased numbers and quality of staff associated with the 2024 reforms lead to improvement in the quality of care for patients and a reduction of negative outcomes, such as avoidable hospitalizations. A study commissioned by CMS found that the increased quality of care resulting from increased staffing would lead to up to $465 million in Medicare savings by reducing medical emergencies and hospitalizations.
The coalition recognizes that the federal budget bill passed in July 2025 called on CMS to implement a replacement regulation. Instead of repealing the existing standards with no replacement, the coalition is urging CMS to put a rule in place that mandates tailored, minimum staffing requirements to prevent long-term care facilities from cutting costs and corners at the expense of patients already vulnerable to abuse and abandonment. The coalition also asserts that proposals from CMS should not preempt existing or future state standards that provide greater protections for residents.
Attorney General Raoul was joined in filing the comment letter by the attorneys general of Arizona, California, Colorado, Delaware, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, and Washington.
