CMS Announces Risk-Based Survey Process for High-Performing Nursing Homes 

CMS has announced the nationwide implementation of a new Risk-Based Survey process for qualifying, high-performing nursing homes. Beginning September 8, 2026, eligible facilities may receive a more focused recertification survey that requires less onsite time and fewer surveyors than the traditional Long-Term Care Survey Process. 

The initiative is intended to help state survey agencies direct limited resources toward facilities where residents may face greater health and safety risks, while reducing survey burden for nursing homes that consistently demonstrate stronger performance. 

As always, Simple continues to monitor regulatory updates like these to help skilled nursing facilities stay informed and prepared. 

What CMS Announced 

In QSO-26-14-NH, issued July 16, 2026, CMS outlined the national implementation of the Nursing Home Risk-Based Survey, or RBS, process. 

The RBS is a modified version of the standard recertification survey. It still reviews all required areas, but uses fewer survey activities, a smaller resident sample and fewer surveyors. According to CMS, an RBS can generally be completed in approximately half the time of a traditional survey.  

CMS began testing the process in 2023 across 22 states and more than 100 facilities. The agency reported that the pilot identified noncompliance and risks to resident health and safety at levels comparable to the traditional survey process.  

What Does Not Change 

The new process does not remove nursing homes from federal survey oversight. 

State survey agencies must continue conducting a standard recertification survey of every nursing home at least once every 15 months. Complaint investigations and other surveys may also continue when concerns arise. 

A state agency may choose to use the traditional Long-Term Care Survey Process for an RBS-qualified facility when there are concerns involving resident health or safety. CMS may also require a traditional survey based on facility concerns or state survey performance.  

Which Facilities May Qualify? 

CMS estimates that approximately 12% of nursing homes nationwide will initially meet the RBS criteria. Preliminary June 2026 data identified 1,560 qualifying facilities out of 14,682 facilities nationally. CMS noted that these figures are subject to change as more recent data are incorporated.  

To qualify, a facility must meet a detailed set of performance and regulatory conditions. Among other criteria, a facility must have: 

• An Overall Five-Star Rating  
• A Staffing Rating of at least three stars  
• No citations involving actual harm, Immediate Jeopardy or substandard quality of care during the applicable survey cycle  
• No failed Payroll-Based Journal staffing-data audit  
• No failed Minimum Data Set audit  
• A health inspection score at or below the state’s 50th percentile  
• No staffing waiver in effect  
• No change in ownership since the last standard survey  
• No designation as a Special Focus Facility candidate  

CMS also included criteria related to survey timing and certain schizophrenia coding patterns.  

Facilities will be evaluated through quarterly qualified-facility lists provided to state survey agencies. Eligibility generally remains in place for six months unless a facility meets a disqualifying condition before its RBS begins. 

What Could Disqualify a Facility? 

Even after appearing on a qualified list, a facility may lose RBS eligibility before the survey begins. 

Disqualifying events include certain new harm-level, Immediate Jeopardy, abuse or substandard-quality citations; pending Immediate Jeopardy investigations; more than three pending non-IJ active intakes at specified priority levels; an approved nursing waiver; or a change in ownership. 

When one of these exclusions applies, the state agency must convert the RBS to a traditional Long-Term Care Survey Process survey.  

A New Care Compare Designation 

CMS will add an icon to the Nursing Home Care Compare profile of facilities that qualify for the RBS. The designation is intended to help consumers and other stakeholders identify nursing homes that meet the program’s higher-performance criteria. 

The qualified-facility list and Care Compare designation are scheduled to become publicly available beginning September 30, 2026, and will be updated regularly. CMS cautioned that processing timelines may create differences between the lists sent to state agencies and the information displayed on Care Compare.  

The designation could become another factor considered by prospective residents, families, referral partners and health systems when comparing nursing homes. However, facilities should remember that the icon reflects qualification under a specific set of CMS criteria and does not prevent future complaints, investigations or traditional surveys. 

What This Means for Nursing Homes 

The RBS program creates an additional reason for nursing homes to monitor performance across multiple areas—not only their Overall Five-Star Rating. 

Staffing, survey history, PBJ accuracy, MDS accuracy, health inspection performance and ownership status can all affect eligibility. CMS noted that, beyond the requirement for an Overall Five-Star Rating, a low Staffing Rating was one of the most common reasons facilities did not qualify under the preliminary criteria.  

For facility and organizational leaders, this means RBS readiness should not be treated as a single-department responsibility. MDS, nursing, staffing, PBJ, quality, compliance and executive teams may all influence the data and outcomes used to determine qualification. 

Practical Steps for Providers 

Facilities may want to begin by reviewing how their current performance aligns with each CMS criterion. 

Key areas to evaluate include: 

• Overall and Staffing Five-Star performance  
• Recent survey findings and complaint investigations  
• PBJ and MDS data accuracy  
• Health inspection performance relative to state benchmarks  
• Staffing waivers or recent ownership changes  
• Processes for monitoring issues that could affect continued eligibility  

Because CMS will refresh qualified-facility lists quarterly, ongoing visibility will be more useful than a one-time review. 

Using Data to Support Ongoing Readiness 

Simple MDS Analytics helps skilled nursing organizations monitor many of the measures and trends that contribute to Five-Star performance and broader quality oversight. 

Through quality-measure monitoring, forecasting, benchmarking and facility-level reporting, teams can gain clearer visibility into current performance and identify areas where closer review may be needed. MDS-focused analytics can also support efforts to improve documentation and coding accuracy before data issues affect quality reporting or performance results. 

Analytics alone do not determine or guarantee RBS eligibility. They can, however, give facility and organizational leaders a more connected view of the information they may need to evaluate quality performance, data accuracy and regulatory readiness. 

Important Dates 

August and September 2026: CMS conducts training for state survey agencies and CMS locations. 

September 8, 2026: Nationwide RBS implementation begins for eligible facilities, based on state survey schedules. 

September 30, 2026: CMS plans to begin publishing qualified facilities and the high-performing facility icon through the Provider Data Catalog and Nursing Home Care Compare.  

Simple Will Continue Monitoring Updates 

The Risk-Based Survey process represents a meaningful change in how CMS may allocate survey resources and recognize qualifying nursing homes. For providers, it also reinforces the importance of maintaining visibility across quality, staffing, survey and resident-assessment data. 

Simple will continue tracking CMS updates related to the RBS program and sharing information to help skilled nursing facilities understand what is changing and how it may affect quality, compliance and survey-readiness workflows.