CMS Risk-Based Nursing Home Surveys: Why Staffing Strategy Matters

What facility leaders should verify in CMS source materials before the national risk-based nursing-home survey implementation scheduled for September 2026.
Use the current CMS implementation memo
CMS announced a national risk-based nursing-home survey implementation scheduled to begin in September 2026 following state-agency training. Facility leaders should review the current QSO memo and later CMS updates because implementation details can change.
Separate staffing support from survey outcomes
Temporary staffing may support a facility's operating plan, but an agency cannot promise survey performance, ratings, citations, or regulatory outcomes. Facilities retain responsibility for compliance, resident care, documentation, and survey readiness.
Confirm Pennsylvania and federal requirements
The Pennsylvania Department of Health maintains links to state nursing-home laws, regulations, guidance, and federal long-term-care requirements. Assignment preparation should begin with the requirements applicable to the facility and professional involved.
Prepare complete assignment instructions
When requesting temporary staff, document the role, unit, shift, reporting contact, arrival process, required experience, and facility-specific requirements. Clear instructions support operational coordination but do not replace the facility's compliance program.



