CMS Issues Memo Outlining Revisions to the State Operations Manual – Chapters 5 & 7

• By: Maureen Carland
• On: 02/02/2026 09:57:54
• In: Quality/Regulatory

The Centers for Medicare and Medicaid Services (CMS) has released a 300-page memo to state survey agencies outlining revisions to chapters 5 and 7 of the State Operations Manual. AHCA's Regulatory team is reviewing the memo and has developed an initial summary with highlights (member log-in required). The AHCA team will continue to review the memo and share additional details.  

Upon initial read, AHCA is pleased to see CMS address improvements that AHCA has advocated for in our Better Way proposals, including (1) timely response to Informal Dispute Resolutions and provision of written rationale for the decision made; and (2) allowance of offsite desk paper reviews for revisits where deficiencies are less serious and do not require onsite observation.  

However, we also have concerns, including inclusion of the Civil Monetary Penalties enforcement expansion designed by the last Administration that AHCA and other stakeholders have opposed. We recognize rulemaking is required to change this policy and will continue to advocate this to the Administration, as well as our additional solutions to rationalize the regulatory environment so that it is fair, balanced, and focused on meaningful ways to improve care for residents.  

Again, the AHCA Regulatory team is thoroughly reviewing the revisions and will release additional resources regarding the changes. CMS directs providers with questions to email them at DNH_TriageTeam@cms.hhs.gov. Members may also email the AHCA Regulatory Team. 
 
Staff contact: mcarland[at]mehca.org