For decades, nursing home leaders have prepared for the standard recertification survey knowing that even high-performing facilities would undergo a comprehensive review. Beginning in September 2026, that approach is changing. The Centers for Medicare & Medicaid Services (CMS) is implementing a new Risk-Based Survey (RBS) process designed to streamline standard recertification surveys for some of the nation's highest-performing nursing homes—a shift that is already reshaping how facility leaders think about nursing home compliance and survey readiness.
CMS estimates that only about 12% of nursing homes will initially qualify. That makes the new process more than a technical change in survey methodology. For nursing home leaders, it raises an immediate question: Could our facility be one of them?
The concept behind the Risk-Based Survey is simple. CMS wants to put more survey resources where the risk to residents appears to be greatest. Rather than devoting the same level of resources to every standard recertification survey, nursing homes with a strong and consistent record of performance may receive a more focused survey requiring less surveyor time and fewer resources. CMS tested the approach through a pilot involving 22 states before moving toward national implementation.
This does not mean high-performing nursing homes will no longer be surveyed or that they receive a free pass. Facilities will continue to receive recertification surveys at least every 15 months, and CMS and State Survey Agencies retain the ability to use the traditional Long-Term Care Survey Process when concerns arise. In simple terms, strong performance may reduce the routine survey burden, but it does not reduce a nursing home's responsibility to maintain quality and compliance every day.
The RBS initiative represents an important shift in the way CMS approaches nursing home oversight. Historically, excellent outcomes benefited residents, staff, a facility's reputation and its Five-Star rating, but a 5-star nursing home still underwent essentially the same standard recertification survey process as other facilities. Under the new approach, consistently high performance may have another tangible benefit: a more streamlined standard survey.
CMS also plans to identify qualifying high-performing nursing homes with a special designation on Care Compare. That means RBS eligibility may become meaningful beyond the regulatory process. Families comparing nursing homes may be able to see that CMS has identified a facility as meeting the criteria for this high-performing group. For operators, that connects survey performance with reputation, consumer visibility and potentially even census.
CMS will evaluate facility eligibility quarterly. To qualify for the Risk-Based Survey process, facilities must meet criteria that include:
5-Star overall rating on Care Compare
3-Star or higher Staffing rating
Accurate and timely submission of required data to CMS
No citations indicating resident harm during the previous standard survey
No citations for substandard quality of care during the previous standard survey
No recent changes in ownership
Additional CMS performance requirements, as applicable
Why staffing matters: Staffing is no longer simply a workforce issue. It affects resident outcomes, Five-Star performance, survey readiness, and now potentially the type of standard recertification survey a facility receives. High performance depends on the entire organization—not any single department.
One of the most important aspects of the new process is that eligibility is evaluated quarterly. A facility cannot simply perform well during survey month. CMS is looking for sustained performance over time.
This creates an important question for leadership teams: Are we consistently operating like a high-performing organization, or are we preparing for survey? Those are very different approaches. The strongest organizations do not wait until surveyors arrive to discover vulnerabilities. They routinely examine their own data, identify emerging risks and intervene before those risks become deficiencies.
A useful starting point is to look at the facility through the same broad areas that influence CMS's assessment of performance. Is the facility currently 5 stars overall, and does leadership understand which domains are helping or limiting that rating? Did the previous survey cycle include citations involving actual harm or substandard quality of care? Are Plans of Correction resulting in sustained improvement rather than temporary fixes?
Staffing deserves the same scrutiny. Leadership should know the facility's current staffing star rating and understand trends in turnover, agency use and workforce stability. Facilities should also be routinely reviewing the accuracy of MDS, staffing and other CMS data submissions. Data accuracy should not be viewed solely as the responsibility of the MDS coordinator or administrative staff; it is an organizational quality issue.
Finally, leadership should consider organizational stability, including recent ownership changes and whether responsibility for quality and regulatory performance is clearly defined. If any of these questions create uncertainty, that uncertainty itself can help identify where improvement efforts should begin.
Know your current overall Five-Star rating.
Review your Health Inspection, Staffing, and Quality Measures ratings.
Identify which domain is the greatest barrier to improving your overall rating.
Have a specific improvement plan for that domain.
Review trends in falls and injuries.
Monitor pressure injuries.
Track unintended weight loss.
Review antipsychotic use.
Monitor hospital transfers and readmissions.
Review complaints and grievances.
Look for relationships between clinical outcomes, staffing, and complaints—not just individual metrics.
Confirm required CMS data are submitted accurately and on time.
Validate that submitted data match the resident record.
Compare reported measures with what is happening at the bedside.
Make sure clinical and operational leaders understand how their documentation affects reported performance.
Regularly ask: “Does our data accurately reflect the care being delivered in our facility?”
Monitor staffing levels—not just whether minimum requirements are met.
Track turnover and retention.
Evaluate agency utilization.
Assess leadership stability.
Monitor employee engagement and morale.
Evaluate communication and teamwork.
Assess staff competency and education needs.
Review workforce trends alongside clinical quality outcomes.
Conduct routine audits before a problem occurs.
Review trends before they become deficiencies.
Talk with frontline staff before surveyors do.
Ask residents and families about their experience before a complaint is filed.
Identify recurring problems rather than treating incidents in isolation.
Perform root-cause analysis when patterns emerge.
Correct systems and processes, not just individual incidents.
Ask: “If surveyors walked in today, would we need to do anything differently?”
Perhaps the most useful question is not, 'Do we qualify?' but rather, 'What is preventing us from qualifying?' If the answer is staffing, investigate staffing. If it is survey performance, examine recurring deficiencies. If it is quality measures, identify which measures are driving performance and whether improvement efforts are producing meaningful change. If the problem is inaccurate or unreliable data, strengthen the processes used for data validation.
Viewed this way, RBS eligibility can become more than another CMS requirement. It can serve as a practical framework for identifying the areas in which an organization has the greatest opportunity to improve.
CMS's Risk-Based Survey initiative creates something nursing homes have not traditionally had: the possibility that sustained high performance can result in a different regulatory experience. With only about 12% of nursing homes expected to qualify initially, earning that distinction may carry real meaning.
But perhaps the most important takeaway is not the shorter or more focused survey. It is what a facility must do to get there: maintain strong staffing, submit accurate data, achieve excellent survey performance, provide high-quality resident care and execute consistently. Those are not simply strategies for qualifying for a Risk-Based Survey. They are the foundation of a high-performing nursing home.
The Risk-Based Survey is a new CMS approach, beginning in September 2026, that directs standard recertification survey resources toward facilities where resident risk appears greatest. Nursing homes with a strong, consistent record of performance may receive a more focused survey requiring less surveyor time.
Eligible facilities generally need a 5-Star overall rating on Care Compare, a 3-Star or higher Staffing rating, accurate and timely CMS data submissions, no citations involving resident harm or substandard care in the previous survey cycle, no recent ownership changes, and any additional CMS performance requirements. CMS estimates only about 12% of nursing homes will initially qualify.
CMS evaluates eligibility quarterly, so facilities need sustained high performance over time rather than a short-term push before survey.
Qualifying facilities still receive a recertification survey at least every 15 months, and CMS or State Survey Agencies can revert to the traditional Long-Term Care Survey Process if concerns arise. What changes is the scope and intensity of the standard survey, not the requirement to be surveyed.
CMS will bgein implementing the Risk-Based Survey nationally in September 2026, following a pilot conducted in 22 states.
Centers for Medicare & Medicaid Services. CMS Modernizes Nursing Home Oversight with New Risk-Based Survey Approach Designed to Highlight High Performance, Encourage Improvement. July 16, 2026.
Centers for Medicare & Medicaid Services. Five-Star Quality Rating System.