The Centers for Medicare & Medicaid Services (CMS) released updated guidance on nursing home Federal Monitoring Surveys for Fiscal Year (FY) 2025. The guidance comes at a time of uncertainty around the new administration’s potential approach to and impact on  regulatory activities, including enforcement.

In the January 2025 update, CMS has removed the Focused Concern Surveys from health surveys for FY 2025. LeadingAge notes that despite the removal of this survey type, the previously identified federal focus concerns, including nurse staffing, unnecessary psychotropic medications, and resident discharge (listed as “facility-initiated discharge in the original memo), all figure prominently in the newly revised Appendix PP  indicating continued focus from surveyors.

The revised guidance on Federal Monitoring Surveys also reallocated the number of health comparative surveys to be conducted in each state. The health comparative survey, also known colloquially as the look-back survey, in when the federal survey team arrives after a standard or complaint survey has been completed by the state agency. Previously, it was required that a minimum of 20% of the Federal Monitoring Surveys in a state be comparative surveys; CMS has adjusted this requirement to state that at least two surveys in every state must be comparative surveys. CMS further clarified that 60% of Federal Monitoring Surveys must be completed on state agency complaint surveys and 40% on state agency recertifications. Of the 60% that must be completed on state agency complaints, up to 10% of the second type of Federal Monitoring Survey, Resource Support Surveys (known colloquially as side-by-side surveys) can be completed on state agency revisits.

For Emergency Preparedness / Life Safety Code (EP/LSC) Federal Monitoring Surveys, CMS added the option for a desk audit. CMS also specified survey mandates, with a requirement that 30% of EP/LSC surveys must be comparative surveys, while the remaining 70% may either be Resource Support Surveys or desk audits, with a limit of 40% for desk audits. Federal Monitoring Surveys on state agency revisits are limited to 20% each for comparative and Resource Support Surveys.

Access the guidance here.