New CMS Survey Model Signals Immediate Shift in Nursing Home Oversight
CMS has announced a new risk-based survey approach for nursing homes, introducing a more targeted framework for oversight while also creating a clearer pathway to recognize high-performing facilities.
Outlined in a recent Quality, Safety, and Oversight Memo, this approach is designed to better align survey activity with facility-level risk. With survey resources remaining constrained, CMS is shifting away from a one-size-fits-all model and toward a process that adjusts survey intensity based on performance history and current indicators.
How the Risk-Based Survey Approach Works
Under the new model, nursing homes that meet specific high-performance criteria may qualify for a streamlined recertification survey. These surveys are expected to require less time and fewer surveyors compared to the traditional long-term care survey process. This allows state agencies to reallocate resources toward higher-risk facilities, including those with recent complaints, lower quality ratings, or indicators of potential harm. The goal is to improve both the efficiency and effectiveness of oversight without increasing overall survey funding.
It is important to note that all facilities will still be surveyed at least every fifteen months. In addition, qualifying for the risk-based approach does not remove the possibility of a full survey. State agencies and CMS can still conduct a standard survey at any time if concerns arise, particularly those related to resident safety or complaint investigations.
Criteria for High Performing Designation
CMS has established specific requirements that facilities must meet to qualify for the risk-based survey process. These criteria are evaluated on a recurring basis and include both quality outcomes and operational stability.
Key requirements include:
- A five-star overall rating on Care Compare
- Demonstrated accuracy and completeness in data submitted to CMS
- No citations for harm or substandard quality of care in the most recent survey cycle
- No recent changes in ownership
These thresholds are intentionally high. CMS estimates that approximately twelve percent of nursing homes will qualify at the start of the program.
New Visibility on Care Compare
In addition to survey changes, CMS will introduce a visible designation for qualifying facilities on the Care Compare tool on Medicare.gov. This will appear as an icon that identifies high-performing nursing homes, making it easier for consumers and families to distinguish facilities based on quality. This added transparency connects regulatory performance more directly to consumer decision-making. Facilities that meet the criteria will not only experience a different survey process but will also gain a visible marker of performance in a public-facing environment.
Timeline and Implementation
The risk-based survey approach is scheduled to begin in September 2026. Prior to implementation, state survey agencies will undergo training to ensure consistency in how the model is applied. At the same time, the high performer designations are expected to go live on Care Compare, aligning survey process changes with public visibility.
Operational Considerations
While the approach introduces efficiencies, it also reinforces the importance of consistency across several areas.
Facilities will need to maintain strong performance across quality measures, staffing, and compliance processes on an ongoing basis. Because qualification is reassessed regularly, short-term fluctuations in performance or data accuracy could impact eligibility.
Accurate and timely data submission is particularly important, as CMS is explicitly incorporating data integrity into qualification criteria. In addition, survey readiness remains a constant requirement since the scope of a survey can expand at any point based on new information or complaints.
Supporting Ongoing Performance
As oversight becomes more closely tied to real-time performance, the ability to monitor and respond to changes quickly becomes increasingly important. Tools like TapestryIQ™ can support this by providing visibility into quality metrics, staffing trends, and emerging risk indicators. This type of insight allows teams to identify potential issues earlier and take corrective action before they impact survey outcomes or public reporting.
