CMS Updates Guidance on Federal Monitoring Surveys

(Feb. 11, 2025) The Centers for Medicare and Medicaid Services (CMS) recently released updated guidance in memorandum QSO 25-06-NH on nursing home Federal Monitoring Surveys (FMS) for 2025. Most notably, they have removed the Focused Concern Surveys (FCS) for the year and reallocated the number of Health Comparative Surveys (HCS) conducted in each state. They have said that all states will have at least 2 Comparatives, and no more than 10. Long-term care health FMS will be comprised of two survey processes aimed at advising and evaluating the State Agency (SA) health surveys: the Resource and Support Surveys (RSS) and the HCS.

The RSS are surveys where the federal surveyors accompany SA surveyors on an initial, standard, revisit, or complaint survey to observe and assess overall SA surveyor team performance and performance related to specific areas of concern and provide real-time guidance, training, and/or technical assistance to address identified performance needs while on site.

The HCS is conducted by federal surveyors in the same facility, after a standard survey or complaint survey is conducted by the SA. The purpose of the HCS is to monitor and evaluate SA performance. This should be conducted within 60 calendar days of the SA survey exit date.

CMS has additionally added the option for a desk audit for Emergency Preparedness (EP)/Life Safety Code FMS, noting that an EP FMS is not conducted during health FMS, even if the health surveyors surveyed for EP regulations.

Contact: Carrie Mosley, cmosley@leadingageny.org, 518-867-8383 ext. 147