Types of CMS Surveys and What Triggers Them
Understanding the CMS Survey Process · 8 min
Standard Annual Surveys
The standard survey is the most comprehensive type of CMS inspection. It occurs approximately every 12 months (with a federal maximum interval of 15 months) and evaluates compliance across all regulatory areas. These surveys are always unannounced and typically last 3-5 days.
During a standard survey, the team reviews quality of care, quality of life, resident rights, administration, pharmacy, dietary, activities, social services, and environmental conditions. The survey team typically includes 3-5 surveyors with different clinical specialties.
Complaint Investigations
Complaint investigations are triggered by reports from residents, families, staff, ombudsmen, or other sources. These focused surveys investigate specific allegations and can happen at any time — including evenings, weekends, and holidays for serious complaints.
The scope of a complaint investigation is initially limited to the specific allegations. However, if surveyors observe other problems during their investigation, they can expand the scope. A complaint investigation about medication errors might uncover staffing problems, infection control issues, or other deficiencies.
The urgency of the investigation depends on the severity of the allegation:
- Immediate Jeopardy allegations: Investigation begins within 2 business days
- Actual harm allegations: Investigation begins within 10 business days
- No actual harm allegations: Investigation within 45 business days
Revisit Surveys
Revisit surveys verify that a facility has implemented the corrective actions described in its Plan of Correction. They typically occur 45-60 days after the original survey.
During a revisit, surveyors focus specifically on the cited deficiencies. They review evidence of corrective actions, interview staff about implemented changes, observe current practices, and verify that monitoring is occurring as described in the POC.
If the revisit confirms compliance, the deficiency is considered corrected. If problems persist, the deficiency remains cited and additional enforcement actions may follow.
Special Focus Facility Surveys
The Special Focus Facility (SFF) program targets nursing homes with consistently poor performance. Facilities are selected based on a history of serious deficiencies across multiple surveys.
SFF facilities are surveyed every 6 months (twice the normal frequency) with heightened scrutiny. The goal is to either improve the facility's performance or remove it from the Medicare/Medicaid programs.
Facilities in the SFF program must show sustained improvement over 18-24 months to graduate from the program. Those that don't improve face escalating enforcement actions and potential termination.