The Centers for Medicare and Medicaid Services (CMS) on July 16, 2026 announced that the Risk-Based Survey (RBS) will be implemented nationwide beginning September 8, 2026.
This new, targeted survey approach, outlined in CMS memo QSO-26-14-NH, will help state survey agencies focus resources to ensure better capacity to attend to complaint investigations and overdue standard recertification surveys. In a statement, LeadingAge president and CEO Katie Smith Sloan called the decision “a significant win–for nursing home residents and families; for providers, including our nonprofit and mission-driven members; and for state regulators.”
CMS estimates that approximately 12% of nursing homes nationwide will qualify for this survey that is expected to take less time and require fewer surveyors compared to traditional standard recertification surveys. Surveyors will continue to survey for compliance with Requirements for Participation, but the process will include a streamlined review of all areas, a smaller resident sample size, and fewer survey activities.
Nursing homes are determined eligible for the RBS based on a combination of Five-Star Quality Rating System ratings, citation history, performance on CMS audits, and other metrics. CMS will provide a list of qualifying nursing homes to the state survey agencies at the end of each quarter. Before selecting a nursing home from the CMS-provided list, state survey agencies will be responsible for ensuring the nursing home has not met any additional disqualifying criteria since the list was released such as harm-level and higher citations, abuse citations, substandard quality of care, or pending intake investigations that have been triaged at certain levels. A complete list of qualifying and disqualifying criteria can be found in Appendix A and Appendix C of QSO-26-14-NH.
Nursing homes that qualify for the RBS will be identified on Nursing Home Care Compare with an icon to help consumers more readily identify high performers. Surveys that were completed with the RBS model will be identified through a footnote on the survey results webpage, on the survey report (form CMS-2567), and in the relevant survey files posted in CMS’ Provider Data Catalog for Nursing Home and Rehab Services.
CMS will be conducting RBS training sessions during August and September 2026, and live “office hours” following the RBS launch. Additionally, training videos, user manuals, and supplementary learning materials will be available on the Quality, Safety & Education Portal (QSEP) and survey materials will be available in the surveyor resources file on the CMS Nursing Homes guidance page.
LeadingAge is pleased with the long-awaited implementation of the RBS model. “Risk based survey is a critical step and a component of our regulatory reform agenda that we’ve asked for continuously in recent years, in comments to and in meetings with CMS; we fully support the agency’s goals of focusing survey resources where they are most needed and recognizing the commitment to care and excellence demonstrated by providers with strong quality records,” said LeadingAge President and CEO Katie Smith Sloan in today’s statement.
An additional priority for reform – ensuring consistency in citation and enforcement – becomes even more important now and LeadingAge will continue efforts to efforts to bring about improvements in the survey and certification process.