April 6, 2026
The Centers for Medicare & Medicaid Services (CMS) has finalized revisions to the State Operations Manual (SOM) governing nursing home surveys and complaint investigations. The guidance was initially released through QSO 26 03 NH on January 30, 2026, with revisions to Chapters 5 and 7, and was subsequently updated in a revised QSO memo issued on April 3, 2026, to further clarify survey timing expectations.
Key Highlights
Longer, more structured survey starts
- Survey teams are expected to remain onsite for at least five consecutive hours on Day 1.
- Surveys must continue on consecutive calendar days (including weekends and holidays).
Expanded use of off hours surveys
- At least 10% of standard surveys must begin off hours (early mornings, evenings, or weekends).
- At least half of these must start on a Saturday or Sunday.
- CMS expects survey timing to vary to reduce predictability.
Greater emphasis on real time operations
- Off hours surveys will focus on staffing, medications, infection control, safety, and overall care conditions that may differ outside normal business hours.
Exit conference updates—medical director focus
- Administrators are now expected to invite the medical director to the exit conference.
- Surveyors will share preliminary findings only; deficiency citations are not final until the official report.
- This change reinforces the medical director's role in clinical oversight, quality, and compliance.
Facilities should be prepared for surveys to start at any time, increased medical director involvement, and closer scrutiny of clinical care, medication management, and staffing across all shifts.
PALTmed will share more details as we continue reviewing the guidance.