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CMS Releases Updated Surveyor Guidance for Nursing Homes

The Centers for Medicare and Medicaid Services (CMS) recently released an updated memo (QSO-26-03-NH) clarifying surveyor guidance for nursing home inspections. The updates build on provisions introduced in a January 30, 2026 memo, with changes to the State Operations Manual (Chapters 5 and 7) taking effect April 30, 2026.
What's Changing
The updated guidance establishes clearer expectations around how long survey teams must be on-site and on what timeline surveys must be completed:
  • First-day on-site minimum: Survey teams must remain in the facility for at least five consecutive hours on the day of entrance. Teams may leave earlier only if all required first-day activities are finished or an emergency arises.
  • Standard surveys: The first two days must be conducted on consecutive calendar days beginning from the date of entrance.
  • Abbreviated surveys: Must also span two consecutive calendar days from entrance, with surveyors on-site for a minimum of five hours per day unless the investigation is completed sooner. Abbreviated surveys may be triggered by complaints, a change in ownership or management, or other indicators of specific concern.
These clarifications are a welcome development for facilities that have experienced surveys being initiated and then left incomplete for days before surveyors return — a situation that creates significant operational uncertainty.
Civil Monetary Penalty Updates
CMS also confirmed that recent Civil Monetary Penalty (CMP) enforcement revisions will be reflected in the CMP Analytic Tool for all enforcement cycles beginning on or after March 31, 2026. Additionally, per-instance CMPs will be publicly displayed on Nursing Home Care Compare starting June 24, 2026. AHCA is following up with CMS for additional details and will keep members informed.
Resources and Questions
An updated webinar series covering the latest memo changes is available on ahcancalED. The AHCA Regulatory Team is conducting a thorough review of all updates — direct any questions to regulatory@ahca.org
Staff contact: mcarland[at]mehca.org
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