CMS Announces National Implementation of Risk-Based Surveys for Nursing Homes
On July 16th, CMS announced the national implementation of risk-based surveys beginning September 8, 2026 via QSO-26-14-NH. This announcement follows several pilots of the risk-based survey process in 22 states and more than 100 facilities since 2023. Under the Program, a “Risk Based Survey” (RBS) is a very streamlined version of the recertification/annual survey. The RBS has fewer activities, fewer total surveyors and is accomplished in half the time of a normal recertification/annual survey.
Wisconsin was one of the states which piloted this process. During the pilot phase anecdotally we have heard positive experiences from both facilities and the state survey agency.
One question that has been asked by AHCA, by WHCA/WiCAL, and by providers in the state’s piloting the process is the criteria by which facilities eligible for the RBS are determined. QSO-26-14-NH in Appendix A and C lay out the qualifying and disqualifying criteria being used for the RBS . The lists of qualifying facilities will be developed and updated quarterly and will be available on Care Compare and the Provider Data Catalog. CMS will also be placing a “trophy icon” on each nursing home’s Care Compare profile page if the home qualifies for the RBS.
According to the data released by CMS as of June 2026, 42 facilities in Wisconsin are eligible for the RBS, accounting for 13% of SNFs in the state (See Appendix D of the QSO). Under the national program, CMS anticipates that 12% of all nursing homes will be eligible. Additionally, Appendix D shows the number of facilities and percent by state of facilities that don’t qualify for RBS and the reason for exclusion.
We encourage you to review QSO-26-14 to learn more about the Program, especially the qualifying and disqualifying criteria. We have not received further information from DQA and the Bureau of Nursing Home Resident Care yet on their interpretation and plans for implementation , but will follow up to members with any further updates that we receive.
