Infection Control: Emerging Issues & Survey Readiness
Infection prevention and control remains one of the most heavily scrutinized areas in long-term care—and for good reason. As we move into 2026, the Centers for Medicare & Medicaid Services (CMS) has shifted from pandemic-era monitoring to a more standardized, integrated survey approach. While separate focused infection control surveys have ended, infection prevention expectations have not relaxed. In fact, surveyors are now evaluating these requirements more comprehensively during standard surveys and complaint investigations. Consider these strategies for integrating infection control into daily operations, staff competencies, and facility assessments…
CMS Focus for 2025–2026: What’s Changed?
CMS is strengthening infection prevention oversight through updated survey procedures that emphasize consistency, documentation, and real-world practice. Beginning in early 2025, focused infection control surveys were merged into the standard survey process. As of July 31, 2025, CMS officially discontinued mandatory Focused Infection Control Surveys for long-term care facilities. Infection-related concerns are now reviewed during routine recertification surveys or triggered through complaint investigations.
This change reflects a transition away from emergency pandemic oversight and back to routine regulatory enforcement—while still maintaining heightened expectations around infection prevention practices.
Facilities that assume infection control is “less of a focus” because the separate survey ended are at significant risk for citations, particularly under F880 (Infection Control).
Key Emerging Infection Control Issues & Survey Risks (2025–2026)
Enhanced Barrier Precautions (EBP)
Enhanced Barrier Precautions are now a primary survey focus. Surveyors will observe whether staff correctly implement gowns and gloves during high-contact resident care activities such as dressing, bathing, transferring, toileting, changing linens, and providing wound care. EBP applies to residents with chronic wounds, indwelling medical devices, and those colonized or infected with multidrug-resistant organisms (MDROs). Facilities must clearly identify which residents require EBP and ensure staff apply precautions consistently—not selectively.
Mandatory Respiratory Illness Reporting
Facilities must continue weekly reporting of COVID-19, influenza, and RSV data through the CDC’s National Healthcare Safety Network (NHSN). Surveyors are increasingly cross-checking NHSN submissions against facility logs, clinical records, and QAPI documentation. Inconsistent or missed reporting may lead to deficiencies.
Infection Preventionist (IP) Competency
Surveyors remain focused on whether the Infection Preventionist is properly trained, designated, and actively overseeing the infection prevention program. Facilities must demonstrate surveillance systems, trend analysis, staff education, and corrective actions. Simply assigning the role is not enough—the IP must be visibly engaged.
Environmental Observations
Environmental cleanliness is under increased scrutiny. Surveyors are observing high-touch surfaces, shared equipment, resident rooms, and dining areas for infection control compliance. Improper cleaning practices, cross-contamination, and lack of accountability often result in infection control citations.
Staffing Levels and PBJ Data
CMS continues to link infection prevention outcomes to staffing adequacy. Payroll-Based Journal (PBJ) data is reviewed alongside infection control findings, especially when surveyors observe rushed care, missed PPE use, or inconsistent hand hygiene.
Facility Assessments
Facilities must demonstrate that their infection control program is grounded in a current, documented facility-wide assessment. Changes in resident acuity, services offered, staffing patterns, or physical environment must be reflected in updated infection prevention plans.
Action Steps to Strengthen Survey Readiness
To reduce risk and improve compliance, facilities should take proactive steps now:
- Train all staff on Enhanced Barrier Precautions, including which residents require EBP and when gowns and gloves must be used.
- Review and update infection control policies to align with March 2024 EBP guidance and current 2025–2026 reporting requirements.
- Conduct mock surveys with a strong focus on F880, environmental observations, PPE use, and staff interviews.
- Audit NHSN reporting accuracy and ensure logs and documentation match submitted data.
- Validate Infection Preventionist competency through training records, meeting minutes, and QAPI involvement.
How Proactive LTC Consulting Can Help
Survey readiness doesn’t happen by chance—contact us to schedule a mock survey and for consulting services to strengthen infection control programs,
Join these upcoming training opportunities:
- February 10, 2026 Infection Control: Emerging issues & Survey Readiness webinar as part of the Survey & Clinical Risk Management Series
- March 18-19, 20267 Infection Preventionist 2-day Virtual Workshop—an intensive SNF IPC program session designed for the SNF/LTC Infection Preventionist
- On-demand: F880 Infection Prevention & Control—Strengthen IPC program and survey readiness thorough a deep dive of the critical elements of F880
Written By:
Angie Hamer, RN, RAC-CT
Senior Consultant
Proactive LTC Consulting
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