Beginning September 8, 2026, the Centers for Medicare & Medicaid Services will implement a new Risk-Based Survey, or RBS, process for qualifying nursing homes nationwide.
The approach is intended to allow state survey agencies to spend less time in facilities with a strong history of performance and redirect limited survey resources toward complaint investigations, overdue surveys, and nursing homes where residents may face greater risk.
CMS estimates that approximately 12% of nursing homes will initially qualify.
What Is a Risk-Based Survey?
The RBS is a modified version of the traditional Long-Term Care Survey Process used for standard recertification surveys.
Qualifying facilities will still be reviewed for compliance with federal health and safety requirements, but the survey may involve:
- A smaller survey team
- A reduced resident sample
- Fewer survey activities
- Approximately half the onsite time of a traditional survey
CMS tested the process in more than 100 facilities across 22 states and reported that it produced findings comparable to the traditional survey process.
A shorter survey does not mean lower expectations. Surveyors may expand their review when observations, interviews, records, complaints, or resident outcomes raise concerns.
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Which Nursing Homes May Qualify?
Facilities must meet a detailed set of performance criteria. Key requirements include:
- A five-star overall rating
- A staffing rating of at least three stars
- No actual harm, Immediate Jeopardy, or Substandard Quality of Care citations during the most recent survey cycle
- A standard survey completed within the previous 18 months
- No staffing waiver
- Successful Payroll-Based Journal and Minimum Data Set audits
- A health inspection score at or below the state’s 50th percentile
- No recent change of ownership
- No Special Focus Facility candidate designation
CMS may also exclude facilities based on certain post-admission schizophrenia diagnoses among long-stay residents.
Based on preliminary June 2026 data, 1,560 of 14,682 nursing homes met the RBS criteria. This represents approximately 12% of facilities nationally.
Eligibility Can Change
Appearing on a qualifying facility list does not guarantee that a nursing home will receive an RBS.
Before beginning the survey, the State Survey Agency must confirm that the facility has not developed new risk factors. A facility may be moved back to the traditional survey process because of:
- A new actual harm, Immediate Jeopardy, abuse, or Substandard Quality of Care citation
- A pending Immediate Jeopardy investigation
- Multiple active complaints or facility-reported incidents
- A nursing staffing waiver
- A change of ownership
State agencies and CMS may also use the traditional survey process whenever concerns about resident health or safety warrant a more extensive review.
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A New Indicator on Nursing Home Care Compare
Beginning September 30, 2026, CMS plans to add an icon to Nursing Home Care Compare profiles for facilities that meet the RBS criteria.
The icon is intended to identify nursing homes that demonstrate higher performance across measures beyond the traditional Five-Star rating. Survey reports and CMS data files will also indicate when an RBS was conducted.
Because eligibility is reviewed regularly, the icon may be removed if a facility no longer meets the criteria.
What This Means for Nursing Home Leaders
The new process places even greater importance on sustained performance.
RBS eligibility depends on more than preparing well for one survey. It reflects the facility’s broader compliance and quality systems, including staffing, complaint management, survey history, data accuracy, resident assessments, and clinical outcomes.
Facilities should review:
- Five-Star and staffing performance
- Recent deficiencies and complaint trends
- PBJ and MDS data accuracy
- Health inspection results
- High-risk clinical systems
- Processes for identifying and correcting emerging concerns
Even nursing homes that do not currently qualify can use the RBS criteria as a framework for identifying improvement priorities.
Strengthen Survey Readiness with Qsource
Survey readiness should be an ongoing operational practice, not a last-minute response to a survey window.
Qsource works with nursing homes to identify vulnerabilities, strengthen compliance systems, and prepare leaders and staff for the realities of the survey process. Support may include:
- Mock surveys and focused compliance reviews
- Survey readiness assessments
- High-risk chart reviews
- Deficiency analysis and corrective action support
- Plan of Correction development
- Immediate Jeopardy prevention and remediation
- QAPI and performance improvement support
- Staff education and leadership coaching
- Regulatory interpretation and ongoing compliance guidance
Whether a facility qualifies for the new Risk-Based Survey or continues to receive the traditional Long-Term Care Survey Process, the foundation remains the same: reliable systems, accurate documentation, informed staff, and consistent resident-centered care.
Qsource brings more than 50 years of healthcare quality improvement experience to help nursing homes prepare with confidence and address risks before they become citations.
Learn more about Qsource’s nursing home survey readiness and compliance support.
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