Risk Based Survey (RBS) Process Starts Sept. 8th— What you Need to Know
The long-awaited Risk Based Survey (RBS) process will be launched nationwide beginning September 8, 2026. CMS began testing this process in 2023 in 22 states with over 100 facilities and found that this modified form of the LTC Survey Process (LRCSP) …“adequately and consistently identified noncompliance and risks to residents ‘health and safety’.
QSO-26-14-NH outlines the Risk Based Survey (RBS) process which will be used for standard recertification surveys and includes a “streamlined review of all the required areas and fewer activities”. The RSB process takes approximately half the time to conduct and includes fewer total surveyors and a smaller number of residents reviewed than the standard LTSCP. The RBS surveys will be conducted in facilities that qualify based on a higher level of performance. Performance factors include:
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- History of fewer citations
- Higher staffing levels
- Fewer hospitalizations
- Other similar indicators of quality
The qualifying facilities will be identified on Care Compare with this icon which will remain on the facility’s profile page until the facility is no longer eligible for the RBS. CMS estimates that approximately 12% of facilities will qualify for the RBS nationwide. Care Compare will also identify if the facility had an RBS survey via a footnote on the webpage that includes survey results, through an indicator in the actual CMS-2567, and in the relevant survey files posted in CMS’ Provider Data Catalog for Nursing Home and Rehab Services.
The QSO document includes several Appendices that address the following:
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- Appendix A: RBS Facility Qualifying Criteria
- Appendix B: RBS Training Schedules
- Appendix C: RBS Facility Disqualifying Criteria
- Appendix D: Qualified Facilities and Exclusions Counts and Percents by State
Appendix A clarifies that in order to qualify, a facility must NOT have any of the following:
- Less than a 5-star Overall Rating
- Less than 3-star Staffing Rating
- Any citation(s) for Actual Harm, or Immediate Jeopardy (IJ), or Substandard Quality of Care (SQC) in the last survey cycle
- More than 18 months without a standard survey
- Any staffing waivers in effect
- Failed Payroll-Based Journal (PBJ) staffing data audit
- Failed resident assessment Minimum Data Set (MDS) audit
- Health Inspection Score higher than the 50th percentile in the state
- Two or more residents aged 65 or older that are coded with diagnosis of Schizophrenia after being admitted without this diagnosis
- A change in ownership since the last standard survey
- Special Focused Facility Candidate
CMS indicates that State Agencies should conduct RBS based on the lists provided to them and the triggering of disqualification criteria, and not based on what is displayed on the Care Compare website.
CMS will provide each State Agency (SA) with a list of facilities qualified for the RBS at the end of each calendar year quarter (March, June, September, and December). Facilities ae eligible for the RBS for six months after the State Agency (SA) receives this quarterly list, unless a facility meets any of the disqualifying criteria after the list is sent. State Agencies may opt to conduct a standard survey using the LTSCP if they have any concerns related to residents’ health and safety, such as reported complaints.
It is the goal of CMS that the Risk Based Survey process will be successful in: addressing Survey Agencies’ budgetary constraints and the staffing shortages; preventing a back-log of standard surveys (from an increased number of complaint visits); and providing incentives to facilities to continue to improve the quality of care they provide to their residents.
Next Steps:
Take the next step in achieving the performance standards that qualify for future Risk Based Survey selection:
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- Schedule a mock survey with Proactive –September dates are still available.
- Join the monthly Survey & Clinical Risk Management webinar series—starting with the August 11, 2026 session Medication Management & Adverse Drug Prevention
- Contact us to learn about an Annual Partner Plan which provides an allocation of nurse consulting support hours to be used over 12-months at a flat monthly installment. Annual Partner Plans allow providers to address in-depth projects, update clinical programs and advance long term goals such as improvement of QMs and Survey outcomes. Add the Proactive team to your lineup and fast-forward success on a budget-friends Annual Partner Plan.
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