Last week, CMS released QSO-26-03-NH, which outlines updates to Chapters 5 and 7 of the SOM which will be effective March 30, 2026. CMS indicates the revisions are planned to ensure thoroughness and consistency in oversight and investigations across the country when allegations of provider non-compliance occur. While the specific details of the updated guidance have not been released, CMS has shared the following:
Chapter 5, which is the chapter relating to complaint procedures, will include changes to:
- Immediate Jeopardy priority definition examples for nursing homes; and
- clarification of off-site investigations.
Chapter 7, which is the chapter that focuses on survey and enforcement processes for SNF/NF, will include changes to (but are not limited to):
- Several areas of guidance, such as survey process and procedures, survey team composition, plans of correction, verifying corrections, survey revisit, offsite revisit paper review, off-hours surveys, resident privacy and confidentiality, exit conference, IJ determination and abatement.
- Variances – nurse staffing, resident room
- Survey enforcement, disposition of CMPs, IDRs, and IIDRs,
- Technical changes and references
In addition, some guidance previously found in Appendix P of the SOM will be moved to Chapter 7. We will keep you updated as more information becomes available!
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