AHPA Briefs
July 24, 2026
CMS Updates Nursing Home Oversight with a Risk-Based Survey Model
On July 16th, the Centers for Medicare and Medicaid Services (CMS) issued its new risk-based survey approach for Medicare- and Medicaid-certified nursing homes and skilled nursing facilities (SNFs) beginning in September 2026. Before this update, the traditional Long-Term Care Survey Process was the default for standard recertification surveys, while CMS tested whether consistently higher-performing facilities could receive a more focused review. Under the new model, qualifying facilities can access a streamlined standard survey process that uses fewer surveyors and takes less time, allowing state survey agencies to redirect capacity where it’s most needed, like serious complaint investigations. CMS estimates that about 12% of nursing facilities will qualify initially.
To qualify, facilities must meet CMS’ criteria each quarter, including:
- A five-star overall rating on Care Compare;
- Accurate data submissions to CMS;
- No citations indicating resident harm or substandard quality of care during the most recent survey cycle;
- No recent change in ownership;
- A qualifying staffing rating.
CMS plans to add an icon to Care Compare identifying facilities that qualify for the risk-based survey process. Both the survey process and the new Care Compare designations are expected to begin in September 2026.
A focused survey won’t mean a facility is exempt from oversight. Every nursing home will continue to receive a standard survey at least once every 15 months, and states must maintain an average survey interval of approximately 12 months. CMS and state agencies may also use the traditional, more comprehensive survey process at a qualifying facility when complaints, reported incidents or other information raise concerns about resident health and safety. The risk-based process doesn’t replace complaint investigations or change the federal health and safety requirements facilities must meet.
CMS intends to concentrate more staff time on facilities where residents face greater risks of poor care or harm. That redirection could particularly benefit populations that have historically had less access to high-performing nursing homes, like communities with limited financial resources. Research has found that Medicare-Medicaid dual-eligible beneficiaries, Black beneficiaries and Hispanic beneficiaries have been more likely to enter one-star SNFs following hospitalization. Other research has found that facilities serving high proportions of Black residents tend to have lower registered nurse and nurse aide staffing and higher hospitalization and emergency department use.
When CMS originally piloted the model in 22 states, it deemed the model a success. However, its press release doesn’t provide detailed results showing how often focused surveys uncovered concerns, how often they were expanded or whether the approach affected deficiency detection and resident outcomes. Those measures will be important as CMS moves from a limited pilot to national implementation.