06/19/2025

Iowa Court Rules in Favor of Attorneys General, LeadingAge States on Staffing Mandate

As reported to LeadingAge Ohio membership yesterday via a late-day alert, the U.S. District Court for the Northern District of Iowa issued a ruling yesterday in the state Attorneys General and LeadingAge states’ challenge to the national nursing home staffing mandate. The ruling grants a motion in the states' favor to vacate the hourly minimum staffing rates and requirement for 24-hour a day registered nurse coverage. However, the court ruled that the provisions of the rule were severable and as such, denied the plaintiffs’ motion to vacate the enhanced facility assessment requirement and Medicaid reporting requirements. 

Speaking to the 24/7 nursing requirement, the order notes that “The 24/7 RN provision replaces the Congressionally-established floor of ‘at least 8 hours per day’ with a floor of 24 hours per day. This is impermissible.”

On the hours-per-resident-day (HPRD) requirement, the order says of the defendant’s (CMS’s) position that “Requiring a specific level of staff per resident is meaningfully different than establishing additional requirements for providers—such as mandating certain qualifications, vaccinations, trainings, among other things. As such, this argument is unpersuasive.”

Earlier this year, a Texas federal judge also struck down the minimum staffing requirement, stating CMS exceeded its authority in establishing the requirement. Following this, the Trump Administration has proceeded with filing an appeal on the Biden-era policy. 

At this point, it is unclear whether the President supports the staffing rule in principle, or if it is an effort by the Administration to preserve a mechanism for cost-savings in the current Congressional budget reconciliation process. Both the House and Senate budget reconciliation bills have included the elimination of the staffing requirements as a cost-cutting measure, purporting to net $22 billion in savings over 10 years.

Questions related to the outcome of the Iowa case may be directed to Susan Wallace, President / CEO of LEadingAge Ohio at swallace@leadingageohio.org. LeadingAge Ohio is one of 20 LeadingAge state affiliates that are co-plaintiffs in the case.