CMS Risk-Based Survey Process Update

• By: Maureen Carland
• On: 08/19/2026 08:33:52
• In: Quality/Regulatory

CMS has announced the national rollout of its Risk-Based Survey (RBS) process, effective September 8, 2026, per QSO-26-14-NH. The RBS is a streamlined version of the standard recertification survey, using a smaller survey team, fewer resident samples, and roughly half the onsite time of the traditional Long-Term Care Survey Process (LTCSP). It's reserved for higher-performing facilities, freeing up state survey agency resources to focus on complaint investigations and the backlog of facilities overdue for a standard survey. CMS estimates about 12% of nursing homes nationwide will qualify; in Maine, that's 13 of 78 facilities.
To qualify, a facility must have a 5-star overall rating, a staffing rating of at least 3 stars, no Actual Harm/Immediate Jeopardy/Substandard Quality of Care citations in the last survey cycle, no active staffing waivers, a standard survey within the last 18 months, and clean PBJ and MDS audits, among other criteria (full list in Appendix A of the memo). CMS will send state survey agencies a qualified facility list quarterly, and eligibility lasts six months from that list unless a facility trips a disqualifying event in the meantime — like a new Immediate Jeopardy citation or a change of ownership. Qualifying facilities will also get a "high performing" icon on their Nursing Home Care Compare profile starting September 30, 2026.
 
Surveyor Resources Now Available
On August 13, 2026, CMS released the surveyor resources for the RBS, posted in the Survey Resources folder on CMS's Nursing Home webpage. These materials are meant to help both surveyors and eligible facilities prepare for the new survey model, and include:

• RBS IP Care Areas and Probes
• RBS Pathways (Critical Element Pathways)
• RBS CMS-802
• RBS Entrance Conference Form
• RBS Facility Tasks Job Aid
• RBS Mapping Document Streamlined
• RBS Procedure Guide
• RBS Screening Job Aid

 
Next Steps
We strongly encourage members to review the full QSO memo and watch for the new "high performing" icon that will identify RBS-qualifying facilities on Nursing Home Care Compare. Given the depth and length of these documents, MHCA's regulatory team will continue reviewing the materials in the resource folder, and information on a member webinar will be available soon.
 
Questions about the nationwide RBS rollout can be directed to the AHCA Regulatory Team.
 
Staff Contact: mcarland[at]mehca.org