CMS to Resume Routine Nursing Home Inspections After COVID Suspension

The Centers for Medicare & Medicaid Services (CMS) announced on Monday that routine inspections for all Medicare- and Medicaid-certified providers and suppliers will resume, after suspending them as part of its response to the COVID-19 pandemic in March.

The agency directed the resumption of onsite revisit surveys, non-immediate jeopardy complaint surveys and annual recertification surveys as soon as resources are available in guidance released on Monday.

The agency had previously required State Survey Agencies to perform targeted infection-control surveys at all of the nation’s more than 15,000 facilities; that task is 99.2% complete, according to an update from the agency on Friday. In the same announcement, it also touted $15 million in civil money penalties (CMPs) for about 3,400 nursing homes during the pandemic.


The surveys that should be resumed when possible are:

  • Onsite visits as specified in the revisit policy in the State Operations Manual, for surveys with end dates on or after June 1
  • Complaint investigations triaged as “Non-Immediate Jeopardy Medium”
  • Annual recertification surveys required to be conducted within 15 months from a provider’s last recertification survey

After the first outbreak of COVID-19 at a skilled nursing facility in Washington state, CMS announced on March 4 that it was going to immediately refocus inspections of SNFs to zero in on compliance with the agency’s infection control policies and suspend all non-emergency survey work. All CMS locations were directed to suspend all enforcement actions except for unremoved Immediate Jeopardy citations.

“Because survey resources were focused on those activities related directly to the COVID-19 pandemic and immediate threats to patient/resident health and safety, other surveys, including revisits for compliance necessary to end an ongoing enforcement cycle, were suspended,” the memo to state survey agency directors noted. “This included stopping the accrual of Denial of Payment for New Admissions (DPNAs) and per day (PD) CMPs.”


Now CMS will be focusing on resolving suspended enforcement cases, while providing guidance to close them out. According to the memo, this process entails:

  • Expanding the Desk Review Policy for Plans of Corrections
  • Processing enforcement cases started before March 23, 2020
  • Processing enforcement cases started on March 23, 2020, through May 31, 2020
  • Processing enforcement cases started on or after June 1, 2020

“At President Trump’s direction, CMS has worked closely with states to complete focused infection control surveys of virtually all nursing homes in the country in just a few months,” CMS Administrator Seema Verma said in the release announcing the resumed inspections. “These surveys fortified health care facilities around the country to prepare for and implement actions to prevent transmission of the virus and provided indispensable insight into the situation on the ground.”

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