Montana agency reports vacancy rate of 40%. The staffing crunch that is hitting the entire home health industry hard is especially crippling for agencies in rural areas. So say many commenters on the 2023 home health proposed rule. Lower reimbursement rates mean less money to pay staff, many letter-writers point out to the Centers for Medicare & Medicaid Services. “Practicing in a rural service area, there are not enough skilled clinicians for available jobs already and the costs of hiring qualified clinical staff is increasing, specifically Registered Nurses,” reports Melissa Nelson in Utah in her comment letter. “This is only going to get worse in coming years since there is a shortage of nurse educators which will translate to worsening nursing shortages,” Nelson predicts. “If HH agencies cannot afford to reimburse clinical staff better, we will be unable to meet guidelines for timely provision of care and patient care will suffer,” she warns. “Wages have had to increase to keep staff from leaving to other higher-paying jobs,” says Brooke Torres in Idaho in her comment letter. “Northern New England is … experiencing a significant shortage of healthcare workers, specifically registered nurses,” reports Visiting Nurse and Hospice for Vermont and New Hampshire CEO Johanna Beliveau in the agency’s comment letter. “Between 2010 and 2018, Vermont saw a decrease in licensed registered nurses of 24.5 percent. This has resulted in more than 350 nurse vacancies for home health and hospice organizations across the state and a 40 percent vacancy for VNH,” Beliveau says. And it’s not over. “We are beginning to see similar trends across disciplines with the next greatest shortage in therapy and personal care services,” Beliveau adds. “Additionally, serving rural communities adds significant cost to VNH with … the increasing need to rely on premium contracted labor (travelers) to meet the demand for services.” “Our vacancy rate has been running 30-40 percent for the past two years,” offers Partners In Home Care Inc. CEO Dianne Hansen in her comment letter. The agency operates in the Missoula, Montana area. “In the past year, salaries rose 18 percent for our nurses and 21 percent for our home health aides, on top of a normal cost of living increase,” notes Donald Carroll with the Cleveland Clinic health system. Under proposed cuts, “the inability of patients from rural and underserved communities to access home health services would be particularly exacerbated. With a current coverage area consisting of 16 counties, many of which are rural, in Northeast Ohio, we would have to review the feasibility of continuing to provide care for such a large geography in light of the significant payment cuts,” Carroll warns. “Like other organizations across the spectrum, rural agencies have struggled to recruit and retain staff over the past two years,” relates Martha Leclerc with Sanford Health, which says it’s the nation’s largest rural health system. “Urban healthcare providers have a large pool of potential employees and can offer higher wages which makes it incredibly difficult to entice an employee to work in a rural area. Our rural agencies routinely have unfilled positions and are constantly competing with hospitals for employees,” Leclerc rues. “The smaller hospitals and communities are having to compete with larger systems that can offer high nursing contracts and sign on bonuses,” relates Joe Monsour Jr., CEO of Allegiance Healthcare in Louisiana. “This is driving up the cost to provide quality care. Measures such as decreased prehospitalization and improved ambulation remains the focus of most home health providers, but a reduction in the competitiveness of the home health market to attract quality staff will have a negative impact on the quality of care in the long term,” Monsour tells CMS in his comment letter.