Medicaid Bill Rebrands 'Private Duty Nursing' and Mandates National Quality Standards for Complex Care

The Continuous Skilled Nursing Quality Improvement Act of 2025 is aiming to overhaul how Medicaid handles high-level, continuous nursing care for its most medically complex beneficiaries. The big move? It officially changes the name of the service from "private duty nursing services" to "continuous skilled nursing services" and, more importantly, requires the federal government to establish national quality standards for this care. This change is set to take effect 18 months after the bill becomes law (SEC. 3).

The Name Change That Actually Means Something

Sometimes, a name change is just bureaucracy, but here it signals a shift in focus. The bill requires the Secretary of Health and Human Services (HHS) to update the regulations (42 C.F.R. 440.80) to reflect this new term. The new definition will specifically require that these services—which are for complex-care patients needing multiple hours of continuous nursing per day, as determined by the state—must be provided by a licensed nurse (RN or LPN). For the families relying on Medicaid to cover the 24/7 care needed for a child with severe medical needs, this change is meant to standardize what "skilled nursing" actually means and ensure it’s delivered by qualified professionals.

Building the National Playbook for Quality Care

The real muscle of this bill is in Section 4, which mandates the creation of national quality standards for continuous skilled nursing services. Within 180 days, the Secretary must convene a working group that includes a wide range of stakeholders: the nurses providing the care, the agencies managing it, State Medicaid officials, and crucially, the patients themselves (Full-benefit dual eligible individuals and Medicaid beneficiaries) and patient advocacy groups. This diverse group is tasked with developing the new standards, which must be published within one year of the group first meeting. For providers, this means new compliance requirements are coming, which could mean new costs, but for patients, it promises a more consistent level of care, regardless of which state they live in.

Clearing the Regulatory Fog and Adding Metrics

Another significant provision clarifies a point of confusion for providers: the Secretary must issue a letter to State Medicaid Directors confirming that continuous skilled nursing providers are not required to follow the same strict conditions of participation designed for traditional home health agencies under Medicare (Title XVIII). This is a practical win for flexibility, acknowledging that continuous care is different from episodic home health visits. However, this flexibility is balanced by Section 5, which requires the Secretary to update the Home and Community-Based Services (HCBS) Quality Measure Set to include new core and supplemental quality measures specifically for these continuous skilled nursing services. These measures must be used by State Medicaid programs and their managed care contractors, ensuring accountability. The Secretary must review and update these measures at least every eight years, meaning the quality bar will be periodically raised based on best practices.