On November 6, 2023, Project PAUSE Chairs Sue Peschin, MHS, President and CEO of the Alliance for Aging Research, and Chad Worz, PharmD, BCGP, FASCP, Executive Director and CEO of the American Society of Consultant Pharmacists, responded to a request for comment on proposed minimum staffing standards for long-term care from the Centers for Medicare and Medicaid Services (CMS).

Project PAUSE (Psychoactive Appropriate Use for Safety and Effectiveness) is an ad hoc coalition of national patient and professional organizations that advocate on clinical, regulatory, and legislative issues in long-term care.

The letter comments on minimum staffing standards for long-term care facilities and discusses concerns related to staffing and antipsychotic medication metrics. Key takeaways from the letter include: 

1. We support the proposal by CMS to strengthen long-term care facility assessment requirements, emphasizing the need for evidence-based, data-driven care for residents’ behavioral health needs. However, we express concerns about the timing, given the staffing crisis in these facilities. 
2. The letter emphasizes the need to separate staffing issues from inappropriate use of antipsychotics, urging CMS to address the antipsychotic use metrics, which create incentives for misdiagnosis and hinder patient-centered care. Antipsychotics are sometimes necessary for patients with dementia to address extreme agitation, delusions, and potential harm. CMS using antipsychotic abuse as a reason for increased staffing needs perpetuates the false narrative that antipsychotics are primarily used as chemical restraints. 
3. The letter calls for a more nuanced approach, considering the impact of staffing changes on patient access to appropriate care, the well-being of nursing staff, and the consequences of outdated metrics in the long-term care system. 

Read the full letter.