The Centers for Medicare & Medicaid Services (CMS) recently announced significant updates to survey timing requirements and clarified expectations around the minimum length of both standard and complaint surveys. These changes are designed to strengthen consistency and thoroughness in oversight and investigations of alleged noncompliance nationwide.
A key update requires survey teams to remain onsite for a minimum of five consecutive hours on the first day of any survey. This applies to all standard health surveys and reinforces the expectation that surveys remain unannounced. CMS emphasized that survey teams should not conduct a brief entrance conference and leave, only to return later. For example, entering a facility on a Friday and not returning until Monday is no longer acceptable.
CMS is also increasing emphasis on off-hour surveys. While the requirement that 10% of surveys be conducted during off-hours remains unchanged, the definition of “off-hours” has shifted to weekdays between 6:00 a.m. and 5:00 p.m. Additionally, CMS recommends varying the start day of annual recertification surveys to better assess staffing patterns across different shifts.
Surveyors are now instructed to begin resident screening immediately upon entry, rather than waiting for a resident roster. They are also expected to remain vigilant for potential concerns in key areas, including:
- Staffing sufficiency
- Abuse and neglect
- Infection control
- Environmental safety
- Accidents and hazards
- Medication errors and storage
- Pain management
- Behavioral health
- Use of restraints
Further changes include a requirement that at least half of all off-hour standard surveys begin on weekends. Facilities selected for these surveys will be identified using a CMS-provided list, and any off-site investigations must receive prior CMS approval.
CMS also announced updates to Civil Monetary Penalties (CMPs), including inflation-based increases. Notably, per-instance CMPs will be publicly displayed on Nursing Home Care Compare beginning June 24, 2026.
These updates reinforce a clear message: survey readiness must be an everyday priority. Facilities should proactively evaluate their operations, staffing, and compliance practices to align with these evolving expectations.
LW Consulting, Inc. is available to help organizations navigate these changes and strengthen their survey readiness strategies.
LW Consulting, Inc. (LWCI) offers a comprehensive range of services that can assist your organization in maintaining compliance, identifying trends, providing education and training, or conducting documentation and coding audits. For more information, contact LWCI to connect with one of our experts!
