HB6592 redefines private duty nursing services as continuous skilled nursing services under the Social Security Act and creates a path to national quality standards for Medicaid. It also directs a rulemaking process to revise federal regulations and requires updated measures for home- and community-based services, with implementation and publishing timelines.
The bill aims to align coverage, licensure, and quality measurement for continuous care provided to complex-care patients in Medicaid, while preserving state flexibility within a federal standard framework.
At a Glance
What It Does
Amends the Social Security Act to redefine private duty nursing as continuous skilled nursing services and sets an 18-month implementation window. It also directs rulemaking to revise CFR 440.80 to reflect the new definition and nursing licensure requirements for complex-care patients.
Who It Affects
States administering Medicaid, private duty nursing providers, licensed nurses (RNs and LPNs), and entities contracting with Medicaid managed care plans.
Why It Matters
Establishes federal standards for a high-need service, promotes consistent care across states, and clarifies provider licensure for continuous skilled nursing in Medicaid.
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What This Bill Actually Does
The bill begins by redefining what Medicaid covers under private duty nursing, replacing that term with continuous skilled nursing services. The change is not immediate; it becomes effective 18 months after enactment, during which federal regulators will update the relevant rules.
A key part of the bill is to create a national working group, within 180 days, that includes providers, beneficiaries, state Medicaid officials, accrediting bodies, and other stakeholders to develop national quality standards for continuous skilled nursing in Medicaid. After the working group is convened, the Secretary must publish these standards within one year after the group’s first meeting, making them available for states, managed care entities, and providers.
Importantly, the Secretary will issue a letter clarifying that home health conditions of participation under traditional Medicare Title XVIII do not apply to these Medicaid providers. The bill also requires updates to home and community-based services, adding continuous skilled nursing to the list of covered HBWS and expanding the HCBS quality measure set to include core and supplemental measures for continuous skilled nursing, with reviews at least every eight years.
The Five Things You Need to Know
18-month deadline to redefine private duty nursing as continuous skilled nursing in statute and to implement rule changes.
Rulemaking to revise 42 CFR 440.80 to define continuous skilled nursing and require licensed nurses.
A federal working group will develop national quality standards for Medicaid continuous skilled nursing.
National standards will be published within one year after the working group’s first meeting.
HCBS waiver services and quality measures will be updated to include continuous skilled nursing, with updates every 8 years.
Section-by-Section Breakdown
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Short Title
This act may be cited as the Continuous Skilled Nursing Quality Improvement Act of 2025.
Definitions
The bill defines key terms: full-benefit dual eligible individuals, Medicaid beneficiary, Medicaid program, private duty nursing services (to be replaced by continuous skilled nursing services), and defines the Secretary and State for purposes of Medicaid title XIX.
Redefinition of private duty nursing services
Section 1905(a)(8) is amended to replace 'private duty nursing services' with 'continuous skilled nursing services.' The amendment becomes effective 18 months after enactment, and CFR revisions will be issued to reflect this change and ensure licensure of nurses for complex-care patients.
Development of national quality standards
A 180-day clock begins for the Secretary to convene a working group consisting of providers, beneficiaries, state officials, accrediting bodies, and other stakeholders to develop national quality standards for continuous skilled nursing in Medicaid. Within one year after the working group’s first meeting, the Secretary must publish the standards after public notice and comment.
Maintaining up-to-date continuous skilled nursing standards
Within 18 months, the Secretary shall update HBWS list to include continuous skilled nursing services as described in the amended statute, and update the HCBS Quality Measure Set to include core and supplemental measures for these services. The Secretary must review and update these measures at least every eight years, with public notice and comment.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Full-benefit dual-eligible individuals who require continuous skilled nursing will benefit from standardized, quality-focused care and consistent licensure expectations.
- Medicaid beneficiaries beyond dual-eligible individuals will gain from uniform standards and clearer quality expectations in private duty nursing services.
- State Medicaid programs will have a shared framework to implement continuous skilled nursing, potentially reducing variation across states.
- Private duty nursing agencies will operate under national quality standards, providing clearer benchmarks and potential eligibility for accreditation alignment.
- Patient advocacy groups and providers’ associations will have a formal channel to influence standards and improvements in care quality.
Who Bears the Cost
- State Medicaid programs will bear costs for implementing the standards, updating waivers, and aligning state requirements with the new measures.
- Private duty nursing providers may incur compliance, training, and reporting costs to meet the new national standards and licensure expectations.
- Federal regulators (Secretary/CMS) will incur administrative costs to convene the working group, publish standards, and maintain ongoing updates to measures.
- Private duty nursing accrediting bodies will face alignment costs to reflect the new standards and measurement sets.
- There may be costs to update information technology and data reporting systems to track quality measures and compliance.
Key Issues
The Core Tension
Balancing the promise of uniform, higher-quality care for complex-care patients against the administrative and financial burden on states and providers to implement and maintain new national standards within varied state Medicaid infrastructures.
The act seeks to standardize a high-need service across Medicaid through national quality standards, which could raise care quality but also imposes new implementation and ongoing compliance costs on states and providers. A major design choice is to move private duty nursing under a National Quality Standards framework while clarifying that COPs for home health agencies under Title XVIII do not apply to these Medicaid providers, reducing regulatory overlap but creating potential gaps in cross-program oversight.
The 18-month implementation window and the periodic eight-year review of measures are intended to keep standards current, but they also raise questions about funding, state capacity, and the speed at which states can adapt their Medicaid waivers and reporting systems.
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