Each year, CMS publishes its Mission & Priorities Document (MPD), the internal roadmap that tells State Survey Agencies how to prioritize nursing home surveys and oversight for the coming fiscal year. The FY2027 MPD is out, and for skilled nursing and long-term care providers, most of it is a continuation of what's already in motion. But two changes are worth understanding clearly.

Change #1: Risk-Based Survey Goes Nationwide

The Risk-Based Survey (RBS) process, a streamlined, shorter version of the standard nursing home survey, has been in pilot testing since 2023 across 22 states and more than 100 facilities. As of September 8, 2026, CMS has moved it from pilot to nationwide implementation.

A quick but important clarification on the name itself: "Risk-Based Survey" does not mean a facility has been flagged as risky. It's the opposite. The name refers to CMS's methodology, using risk data to identify which facilities are safe to receive a shorter, less intensive survey. Qualifying for RBS is a favorable designation reserved for top-tier performers. It is not a citation, a warning, or a survey trigger of any kind.

Here's what that means in practice:

• Only facilities meeting a strict set of quality criteria qualify: a 5-star overall rating, 3-star or higher staffing rating, no recent citations for actual harm or immediate jeopardy, no staffing waivers, no failed data audits, and several other conditions. Per CMS's own figures, roughly 12% of nursing homes nationwide currently qualify.
• Qualifying facilities are eligible for RBS for six months after their State Survey Agency receives the quarterly qualified list, unless a disqualifying event occurs in the meantime.
• Starting September 30, 2026, CMS will publicly display a "High Performing Facility" icon on the Nursing Home Care Compare website for qualifying facilities, updated on a regular basis.

One detail directly from CMS's own guidance is worth flagging for accuracy: CMS itself notes there will be differences between the qualifying list sent to states and what's displayed publicly on Care Compare at any given time, due to data processing timing. States are instructed to survey based on their official list, not the public website. In other words, the public icon is a general indicator, not a real-time guarantee: a distinction that matters if you're using it to gauge a facility's current status.

Change #2: A New Limit on Special Focus Facility (SFF) Survey Timing

Special Focus Facilities, nursing homes identified by CMS as having a pattern of serious quality problems, are required to receive a standard recertification survey at least once every 186 days. The FY2027 MPD adds a clarification that didn't exist in the prior year's release: a complaint survey may be used to extend that 186-day window only once during a facility's time as an SFF. After that, the standard survey clock runs without exception.

This is a narrow but real tightening of oversight for facilities already under heightened scrutiny.

Everything Else: Status Quo

Outside of these two items, the FY2027 priorities restate what was already in place for FY2026:

• The four-tier prioritization structure for surveys and complaint investigations is unchanged.
• The 15.9-month maximum interval and 12.9-month statewide average for standard recertification surveys remain the same.
• The 10% off-hours survey requirement (with at least half on weekends) is unchanged.
• CMS's nursing home staffing campaign continues, with expanded mechanisms for funding incentives through 2026–2027.

The Takeaway

In summary, RBS is no longer a pilot; it's live nationwide, and despite the name, it is a mark of distinction, applying only to a small, high-performing slice of the industry. And SFFs now have a firm cap on how many times a complaint survey can buy extra time before a standard survey is due. Everything else is CMS staying the course.

Source: CMS QSO-26-14-NH, "Nursing Home Risk-Based Survey National Implementation" (July 16, 2026); CMS Fiscal Year 2027 Mission & Priorities Document.

About the Author

Greg Seiple

Vice President - Clinical Informatics

Greg Seiple's journey in Long Term Care began as a nursing assistant in 1993, while pursuing his nursing degree. Over 19 years with HCR ManorCare, he progressed from various facility roles to Assistant Vice President in Clinical Services. Greg's expertise extends to VP and SVP roles in corporate clinical teams. Now, as VP of Clinical Informatics at SHP/IntelliLogix, he brings a wealth of experience. Additionally, Greg shares his knowledge as an adjunct instructor at Penn State University, teaching in the Nursing Home Administrators course.