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Policy Snapshot

February 2, 2026

The Centers for Medicare & Medicaid Services (CMS) has announced updates to the State Operations Manual (SOM), introducing revised and clarified guidance to strengthen survey and enforcement processes.

CMS is releasing the following guidance in Chapter 5 of the SOM: 

  • Revisions to immediate jeopardy priority definition examples for nursing homes
    Clarification of off-site investigations

CMS has updated and revised guidance in Chapter 7 of the SOM that includes: 

  • Survey team composition, survey procedures, plans of correction, verifying corrections, survey revisit and off-site revisit paper review, off-hours survey, enforcement, nurse staffing waivers, and disposition of Civil Money Penalties (CMP), Federal Civil Penalties Inflation Reduction Act, Informal Dispute Resolution (IDR), and Independent Informal Dispute Resolution (IIDR)
  • Guidance previously found in Appendix P of the State Operations Manual
  • Technical changes that include updates for accurate references

All of the updates can be viewed here.