Major CMS Revisions to Nursing Home Surveyor Guidance: What Owners Need to Know for 2025

The Centers for Medicare & Medicaid Services (CMS) has issued significant updates to the Long-Term Care (LTC) Surveyor Guidance, with implementation now set for March 24, 2025.1 These changes introduce enhanced oversight, compliance expectations, and refinements to key nursing home regulations.

Key Revisions to CMS Guidance

The revised guidance, originally issued under QSO-25-07-NH2 and later updated under QSO-25-12-NH, covers various areas of resident care, compliance, and facility operations. Below are some of the more noteworthy updates:

1. Admission, Transfer & Discharge Updates

• Stricter Admission Agreements: Facilities may no longer include contract language that requires third-party payment guarantees.1
• Redefining Compliance: CMS has deleted certain regulatory tags (F622–F626, F660–F661) and introduced new ones (F627 & F628) to streamline compliance assessments.2
• Enhanced Oversight on Transfers & Discharges: There is more explicit guidance on inappropriate discharges and resident transfer rights.2

2. Nursing Services & Payroll Based Journal (PBJ) Reporting

• Stronger Staffing Compliance Measures: CMS will now use Payroll Based Journal (PBJ) Staffing Data Reports as a primary tool to assess staffing compliance.1.
• Revised Director of Nursing (DON) Requirements: New investigative guidelines for DON responsibilities and facility staffing requirements.1

3. Medication & Chemical Restraints Reform

• Psychotropic Medication Oversight: The use of psychotropic medications is now consolidated under F605 to prevent unnecessary medication use.1
• Tighter Regulations on Medication Use for “Convenience”: CMS clarifies that medications should not be used to sedate residents or reduce staff workload.1
• Resident Rights Emphasized: Facilities must obtain explicit consent before initiating or increasing psychotropic medication.1

4. Quality Assurance & Performance Improvement (QAPI)

• Health Equity Considerations: Facilities must now analyze disparities in care among different racial, socioeconomic, and linguistic groups.1
• Expanded Root Cause Analysis: Health equity factors must be considered when investigating medical errors and adverse events.1

5. Physical Environment & CPR Certification

• Revised Construction Requirements: Nursing homes certified after November 28, 2016, can meet certain occupancy requirements without major renovations.1
• Updated CPR Training Requirements: Certification standards now align with nationally accepted CPR protocols.1

Steps Nursing Homes Can Take Now

With these significant updates set to take effect in March 2025, nursing home operators may want to consider the following:

✅ Review Admission Agreements: Ensure compliance with new restrictions on third-party payment guarantees.

✅ Enhance Staffing Practices: Leverage Payroll Based Journal (PBJ) data to monitor and maintain adequate staffing levels.

✅ Reassess Medication Policies: Strengthen oversight on psychotropic drug use and ensure informed resident participation.

✅ Update Medical Director Responsibilities: Ensure adherence to professional standards and documentation accuracy.

✅ Revamp QAPI Programs: Integrate health equity measures into quality assessments.

✅ Train Staff: Utilize CMS’s Quality, Safety & Education Portal (QSEP) for new training resources.3

Final Thoughts

Nursing home owners may need to consider taking action to remain in compliance, and to avoid citations and any perception of not maintaining high-quality care.

For legal guidance on implementing these changes, contact the Long-Term Care Team at Sandberg Phoenix & von Gontard P.C.

Citations

1.) Centers for Medicare & Medicaid Services (CMS), QSO-25-12-NH, January 15, 2025. Available at: https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos-states-and-cms-locations.

2.) Centers for Medicare & Medicaid Services (CMS), QSO-25-07-NH, November 18, 2024. Available at: https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos-states-and-cms-locations.

3.) CMS Quality, Safety, and Education Portal (QSEP). Available at: https://qsep.cms.gov/welcome.aspx.

Additional Sources

4.) McKnight’s Long-Term Care News. CMS Issues Significant Survey Changes for 2025. Available at: https://www.mcknights.com/news/breaking-cms-issues-significant-survey-changes-for-2025.

5.) Kansas Association of Broadcasters (KABC). CMS Issues Major Updates to Nursing Home Care Guidelines. Available at: https://www.kabc.org/cms-issues-major-updates-to-nursing-home-care-guidelines.