Category: CMS Memo

QSO-26-03-NH: Revisions to the State Operations Manual (SOM) Chapters 5 and 7

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QSO-26-03-NH: Revisions to the State Operations Manual (SOM) Chapters 5 and 7 – CMS issued a memo and revisions to the State Operations Manual (SOM) Chapters 5 and 7, effective March 30, 2026.

Memorandum Summary

CMS is releasing the following guidance in Chapter 5 of the SOM:

  • Revisions to Immediate Jeopardy Priority Definition examples for Nursing Homes; and
  • Clarification of Off-site investigations.

CMS has updated and revised guidance in Chapter 7 of the SOM that includes:

  • Survey Team Composition, Survey Procedures, Plans of Correction, Verifying Corrections, Survey Revisit and Offsite Revisit Paper Review, Off-hours Survey, Enforcement, Nurse Staffing Waivers, Disposition of Civil Money Penalties (CMP), Federal Civil Penalties Inflation Reduction Act, Informal Dispute Resolution (IDR), and Independent Informal Dispute Resolution (IIDR);
  • Additionally, guidance previously found in Appendix P of the State Operations Manual has been added to Chapter 7; and
  • Technical changes that include updates for accurate references.

CMS – QSSAM Memo

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QSSAM-26-01-NH Impact of iQIES (Internet Quality Improvement and Evaluation System) Transition on Nursing Home Care Compare

On 1/9/26, CMS issued a QSSAM memo regarding the impact of IQIES on Nursing Home Care Compare Website.

Memorandum Summary

  • CMS recently transitioned to a cloud-based Internet Quality Improvement and Evaluation System (iQIES) for nursing home survey and certification data. This transition has introduced some data discrepancies that may be reflected on Nursing Home Care Compare. Our technical team is actively working to address transition-related differences. Providers should submit specific concerns to BetterCare@cms.hhs.gov.
  • CMS is also evaluating how complaint information is presented on Nursing Home Care Compare. During this evaluation, CMS will be removing the number of complaint allegations and the number of facility reported incidents from Nursing Home Care Compare, beginning February 25, 2026. Information related to official complaint surveys and complaint citations issued as a result of those investigations will continue to be available on Nursing Home Care Compare.

Please see the full memo, QSSAM-25-1-ALL, on CMS’ website.

QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown

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QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown 10.31.2025

Memorandum Summary

Pursuant to the federal government shutdown, we are doing our utmost to:

  • Protect Medicare and Medicaid beneficiaries against immediate dangers to life and health, and
  • Prevent providers and suppliers from experiencing interruptions that would threaten their ability to provide healthcare services that are vital to Medicare and Medicaid beneficiaries.

In this memorandum we identify functions that (a) are not affected by a Federal shutdown, (b) excepted functions that are to be continued in the event of a shutdown (also referred to as “essential functions”), and (c) other activities that are directly affected, are not legally authorized to be performed, and therefore should not be operational during a Federal shutdown.

For full details, please see QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown.

Federal Shutdown

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The Centers for Medicaid and Medicare Services has issued a memo regarding the federal shutdown. Please read through the memo for full details as it describes certain activities that the Department of Health and Senior Services (or their contractors) currently does not have the authority to conduct – including revisits (unless certain circumstances apply), informal dispute resolutions, recertification surveys, and issuance of 2567s for citations that do not allege harm or greater.

https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-regions/contingency-plans-state-survey-certification-activities-event-federal-government-shutdown

Temporary Pause of Nursing Home Compare Updates

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CMS recently transitioned to a cloud-based Internet Quality Improvement and Evaluation System (iQIES) for nursing home survey and certification data. To ensure accuracy of publicly reported information during this transition, Nursing Home Care Compare updates will be temporarily paused as of July 30, 2025. Updates will resume in October 2025. This temporary pause allows CMS to ensure the accuracy and reliability of publicly reported nursing home quality information. QSSAM-25-03-NH

CMS Memo Updates

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The Focused Infection Control (FIC) survey is retired as of 07-31-2025. Items in the downloads section on the Nursing Home webpage have been updated to align with the revisions to QSO-25-23-ALL.

According to CMS’ website, this also includes QSO 23-10- which contained the requirement for Enhanced Enforcement for Infection Control Deficiencies. EXPIRED: Strengthened Enhanced Enforcement for Infection Control

Additionally, CMS has posted on their website a revision/expiration of QSO-19-07-NH-Enhanced Oversight and Enforcement of Non-Improving Late Adopters/unnecessary psychotropics. EXPIRED: Enhanced Oversight and Enforcement of Non-Improving Late Adopters | CMS

All CMS QSO memos can be found at: Policy & Memos to States and CMS Locations | CMS.

CMS Memo: QSO-25-19-ALL: Release of CMS-2567: Statement of Deficiencies and Plan of Correction

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Memorandum Summary

  • CMS is committed to the transparency of quality of care findings, so that patients, residents, and their families can make informed health care decisions.
  • The official Form CMS-2567: Statement of Deficiencies and Plan of Correction (CMS-2567) will be publicly releasable within 14 days after receipt by the provider, supplier, or lab. In other words, the CMS-2567 can be immediately released upon receipt by the provider/supplier.
  • This update aligns with the Nursing Home CMS-2567 process, which per regulation, are releasable within 14 days of transmission to the facility (See 42 CFR 488.325).
  • This guidance does not apply to Accrediting Organization (AO) survey findings, except those related to surveys of Hospice and Home Health Agencies.

Please see the full memo for details located at https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-and-cms-locations/release-cms-2567-statement-deficiencies-and-plan-correction.

CMS Memo: QSO-25-11-NH: Long-Term Care (LTC) Facility Acute Respiratory Illness Reporting Requirements

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Memorandum Summary

  • Acute Respiratory Illness Reporting Requirements: The LTC facility requirements for reporting COVID-19-related data expired on December 31, 2024, except for reporting COVID-19 resident and staff vaccination status. On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2025 Home Health Prospective Payment System Rate Update. The rule broadens the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) reporting requirements for nursing homes. Beginning on January 1, 2025, LTC facilities are required to electronically report information about COVID-19, influenza, and respiratory syncytial virus (RSV) in a standardized format and frequency specified by the Secretary.
  • Survey Process and Enforcement: CMS expects LTC facilities to comply with all facility requirements. These requirements will be incorporated into the survey process once guidance to LTC facility surveyors is released.

Please see the full memo for details located at https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-and-cms-locations/long-term-care-ltc-facility-acute-respiratory-illness-reporting-requirements.

NOMNC

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SLCR recently had an opportunity to meet with Livanta, the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) that receives the appeals of non-coverage (SNF ABN and NOMNC) required in F582. A couple items to note- the required forms are updated periodically- so please make sure the most recent forms are being used. The most recent forms and instructions for their use can be found here: Beneficiary Notices Initiative (BNI) | CMS. Changes were made in November 2024 and additional changes will be effective beginning January 1, 2025.

SLCR has heard recent concerns from facilities and residents regarding Medicare Advantage beneficiaries being denied services or delays in services. If you hear these concerns, please share with Medicare Advantage residents and/or families that the NOMNC has been modified to reflect regulations providing enrollees additional fast-track appeal rights when they untimely request an appeal to the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO), or still wish to appeal after they end services on or before the planned termination date (See: CMS-4205-F, p. 30827).

These notices should be provided timely to beneficiaries whose Medicare covered services will end to inform them of their rights and protections related to financial liability and appeals under the Fee-for-Service Medicare and Medicare Advantage (MA) programs.

Additionally, facilities and beneficiaries can find contact information for Missouri’s BFCC-QIO, Livanta, here: https://www.livantaqio.cms.gov/en/states/missouri.

CMS Memo: QSO-24-21-NH: Compliance with Residents’ Rights Requirement related to Nursing Home Residents’ Right to Vote

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Memorandum Summary

  • The Centers for Medicare & Medicaid Services (CMS) is affirming the regulatory expectation that ensures nursing home residents have the unimpeded ability to exercise their right to vote as a citizen of the United States.
  • Nursing homes must ensure residents are able to exercise their Constitutional right to vote without interference, coercion, discrimination, or reprisal from the facility.
  • States, localities, and nursing home owners and administrators should collaborate to support a resident’s right to vote.

Please see the full memo for details located.

CMS Memo: QSO-24-14-NH: Nursing Home Data and Care Compare Updates

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Memorandum Summary

  • Update Nursing Home Guides Posted on the Medicare.gov Care Compare website: CMS will post new guides for consumers on the Medicare.gov Nursing Home Care Compare website to further support consumers choosing a nursing home and those already admitted to a nursing home.
  • Implement the New Staffing Level Case-Mix Methodology: CMS will implement the new staffing level case-mix adjustment methodology, announced in September 2023 (QSO-23-21-NH), for staffing measures reported on Nursing Home Care Compare.
  • Revise the Staffing Turnover Methodology: CMS will revise the nursing home staffing turnover methodology so that employees who are on leave for 90 days or less are not counted as staff turnover.
  • Post Facility Data: To increase transparency CMS, will post data on characteristics of nursing homes and their residents on cms.gov.

CMS Memo: QSO-24-08-NH: Enhanced Barrier Precautions in Nursing Homes to Prevent Spread of Multidrug-resistant Organisms (MDROs)

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Memorandum Summary

  • CMS is issuing new guidance for State Survey Agencies and long term care (LTC) facilities on the use of enhanced barrier precautions (EBP) to align with nationally accepted standards.
  • EBP recommendations now include use of EBP for residents with chronic wounds or indwelling medical devices during high-contact resident care activities regardless of their multidrug-resistant organism status.
  • The new guidance related to EBP is being incorporated into F880 Infection Prevention and Control.

Please see the full memo for complete details at https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos-states/enhanced-barrier-precautions-nursing-homes-prevent-spread-multidrug-resistant-organisms-mdros.

If you have questions regarding implementing EBP in your long-term care facility, please contact the Healthcare-Associated Infections/ Antimicrobial Resistance program at 573-751-6113.

CMS Memo: QSO-23-18-NH: Posting of Nursing Home Ownership/Operatorship Affiliation Data on Nursing Home Care Compare Website and data.cms.gov

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Memorandum Summary

  • Posting Nursing Home Affiliation on Nursing Home Care Compare: CMS will include ownership and operatorship affiliation information on our Nursing Home Care Compare website.
  • Posting Aggregate Nursing Home Performance Data on data.cms.gov: CMS will publish combined inspection, staffing, quality, and other performance metrics across groups of nursing homes with shared ownership and operatorship on data.cms.gov.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/1519889558/posting-nursing-home-ownership/operatorship-affiliation-data-nursing-home-care-compare-website-and.

Updated CMS Memos Related to COVID-19

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CMS released the two memos below this past week. Homes may begin to change their policies and procedures and implement current CDC guidance.

QSO-20-38-NH Testing Expired
QSO-20-39-NH Visitation REVISED

Here is the link to the current CDC guidance for nursing homes: https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control-recommendations.html#create.

CMS Memo: QSO-23-13-ALL: Guidance for the Expiration of the COVID-19 Public Health Emergency (PHE)

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Memorandum Summary

  • Social Security Act Section 1135 emergency waivers for health care providers will terminate with the end of the COVID-19 Public Health Emergency (PHE) on May 11, 2023.
  • Certain regulations or other policies included in Interim Final Rules with Comments (IFCs) will be modified with the ending the PHE. Certain policies, such as the Acute Hospital at Home initiative and telehealth flexibilities have been extended by Congress through December 31, 2024.
  • Long Term Care and Acute and Continuing Care providers are expected to be in compliance with the requirements according to the timeframes listed below {in the memo}.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/guidance-expiration-covid-19-public-health-emergency-phe.

CMS Memo: QSO-23-10-NH: Strengthened Enhanced Enforcement for Infection Control Deficiencies and Quality Improvement Activities in Nursing Homes

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Memorandum Summary

  • CMS has rescinded memorandum QSO-20-31-ALL, the Enhanced Enforcement for Infection Control Deficiencies, and replaced it with memorandum QSO-23-10-NH, revised guidance for Strengthened Enhanced Enforcement for Infection Control Deficiencies. This revised guidance strengthens enforcement efforts for noncompliance with infection control deficiencies. The enhanced enforcement actions are more stringent for infection control deficiencies that result in actual harm or immediate jeopardy to residents. In addition, the criteria for enhanced enforcement on infection control deficiencies that result in no resident harm has been expanded to include enforcement on noncompliance with Infection Prevention and Control (F880) combined with COVID-19 Vaccine Immunization Requirements for Residents and Staff (F887).
  • CMS is providing guidance to the State Survey Agencies and CMS locations on handling enforcement cases before and after the revisions of Enhanced Enforcement for Infection Control Deficiencies.
  • Quality Improvement Organizations have been strategically refocused to assist nursing homes in combating COVID-19 through such efforts as education and training, creating action plans based on infection control problem areas, and recommending steps to establish a strong infection control and surveillance program.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/strengthened-enhanced-enforcement-infection-control-deficiencies-and-quality-improvement-activities.

CMS Memo: QSO 18-24-ESRD: Guidance and Survey Process for Reviewing Home Dialysis Services in a Nursing Home (REVISED 3/22/2023)

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Memorandum Summary

  • Dialysis Services in a Long-Term Care (LTC) Facility: In 2018, CMS issued guidance that addressed care at home provisions for nursing home residents that were receiving home dialysis. Since that time, CMS has received questions, comments, and feedback from the state survey agencies, the dialysis provider community, as well as other Federal and non-Federal stakeholders. This memorandum addresses those questions and incorporates the feedback that we received.
  • Survey Process for Evaluation of Home Dialysis in an LTC Facility: The End-Stage Renal Disease (ESRD) Core Survey Process has been updated to include additional survey activities which evaluate dialysis services provided by an ESRD facility to residents in an LTC facility.
  • Attachments: Included as an attachment to this memorandum is an advance copy of the survey procedures for ESRD surveyors reviewing dialysis in nursing homes.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/guidance-and-survey-process-reviewing-home-dialysis-services-nursing-home.

CMS Memo: QSO 23-06-ALL: Provider and Supplier Compliance Education Through Quality in Focus (QIF) Trainings

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Memorandum Summary

Quality in Focus: CMS developed a series of short (10–15 minutes), Quality in Focus interactive videos tailored for specific provider types. The series aims to increase the quality of care for people with Medicare and Medicaid by reducing the deficiencies most commonly cited during the CMS survey process, such as infection control and accident prevention.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/provider-and-supplier-compliance-education-through-quality-focus-qif-trainings.

CMS Memo: QSO 23-05-NH: Updates to the Nursing Home Care Compare Website and Five Star Quality Rating System: Adjusting Quality Measure Ratings Based on Erroneous Schizophrenia Coding, and Posting Citations Under Dispute

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Memorandum Summary

  • Adjusting Quality Measure Ratings: CMS will be conducting audits of schizophrenia coding in the Minimum Data Set data and, based upon the results, adjust the Nursing Home Care Compare quality measure star ratings for facilities whose audits reveal inaccurate coding.
  • Posting Citations Under Dispute: To be more transparent, CMS will now display citations under informal dispute on the Nursing Home Care Compare website.

Please see the full memo for complete details at https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/updates-nursing-home-care-compare-website-and-five-star-quality-rating-system-adjusting-quality.

CMS Memo: QSO-23-01-ALL: The Importance of Timely Use of COVID-19 Therapeutics

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Memorandum Summary

  • Providers and suppliers, especially those delivering care in congregate care settings, should ensure their patients and residents are protected against transmission of COVID-19 within their facilities, as well as receiving appropriate treatment when tested positive for the virus.
  • Further, all providers and suppliers should continue to implement appropriate infection control protocols for COVID-19 (https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control.html) and Influenza (https://www.cdc.gov/flu/professionals/infectioncontrol/index.htm).
  • This memo discusses the importance of the timely use of available COVID-19 therapeutics, particularly for high-risk patients who test positive for the virus.

Please see the full memo for complete details at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/importance-timely-use-covid-19-therapeutics.

CMS Memo: QSO-23-02-ALL: Revised Guidance for Staff Vaccination Requirements

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Memorandum Summary

  • CMS is committed to taking critical steps to protect vulnerable individuals to ensure America’s health care facilities are prepared to respond to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE).
  • On November 5, 2021, CMS published an interim final rule with comment period (IFC). This rule establishes requirements regarding COVID-19 vaccine immunization of staff among Medicare- and Medicaid-certified providers and suppliers.
  • CMS is revising its guidance and survey procedures for all provider types related to assessing and maintaining compliance with the staff vaccination regulatory requirements.
  • This memorandum replaces memoranda QSO 22-07-ALL Revised, and QSO 22-09-ALL Revised, and QSO 22-11-ALL Revised to consolidate the information into a single memorandum. The guidance in this memorandum applies to all states.

Please view the latest CMS memo regarding revisions to SSF program at https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/revised-guidance-staff-vaccination-requirements.