Top Deficiencies of 2025 & Compliance Trends Heading Into the New Year

Top Deficiencies of 2025 & Compliance Trends Heading Into the New Year

 

As we move into the new year, nursing homes continue to navigate an increasingly complex regulatory environment. While enforcement priorities remain consistent in many areas, how surveyors are applying severity and where they are focusing their time is evolving. Let’s review FY 2025 deficiency data–considering where compliance risk remains highest and what to expect regarding survey activity in the new year.

 

Top Deficiencies Cited in 2025

FY 2025 data shows that many of the most frequently cited deficiencies remain familiar to long-term care providers, including:

• F880 – Infection Prevention & Control
• F689 – Accident Hazards, Supervision & Devices
• F812 – Food Procurement, Storage, Preparation & Service
• F684 – Quality of Care
• F656 / F657 – Care Planning & Revisions
• F755 / F761 – Pharmacy Services & Medication Management
• F600 / F609 – Abuse, Neglect & Reporting of Alleged Violations
• F695 – Respiratory/Tracheostomy Care & Suctioning
• F641 – Accuracy of Assessments (MDS)

While these tags are not new, surveyors continue to cite them when facilities demonstrate gaps in systems, documentation, and follow-through. Let’s examine key trends.

 

Compliance Trend #1: Harm-Level Deficiencies Are Lower in Volume — but More Targeted

A review of CMS QCOR data shows that the total number of harm-level (G–L) deficiencies declined in FY 2025 compared to prior years:

• 2022: 6,824
• 2023: 7,543
• 2024: 7,962
• 2025: 4,791

This decrease suggests that, nationally, surveyors are not issuing harm-level citations at higher volumes. However, this does not mean enforcement intensity has eased.  Instead, surveyors are applying higher severity in targeted, high-risk situations, particularly when deficiencies reflect systemic failures, delayed responses, or inaccurate reporting rather than isolated events.

 

Compliance Trend #2: Falls With Major Injury Remain a High-Risk Focus

Falls with major injury continue to be one of the most scrutinized areas in nursing homes. A recent Office of Inspector General (OIG) study found that 43% of falls with major injury resulting in hospitalization were not reported on the MDS.

As a result, surveyors are:

• Reviewing incident logs more closely
• Cross-checking medical records and hospital transfers
• Assessing whether MDS coding aligns with clinical documentation
• Evaluating patterns of underreporting rather than single events

Facilities with inconsistent fall documentation or reporting practices face increased risk for both regulatory citations and audit findings.

 

Compliance Trend #3: MDS Accuracy Is Now a Regulatory Priority

MDS accuracy is no longer viewed solely through a reimbursement or quality reporting lens. CMS has implemented the SNF Validation Program, which audits MDS data used in Quality Reporting Program (QRP) and Value-Based Purchasing (VBP) measures.

Facilities selected for validation must submit supporting documentation for review. While most results are informational, failure to respond or submit records timely results in a 2% reduction to the Annual Payment Update.

Surveyors are also increasingly citing:

• F641 – Accuracy of Assessments
• Care planning deficiencies linked to inaccurate MDS coding
• Inconsistencies between documentation, interviews, and reported data

 

Compliance Trend #4: Documentation Gaps Drive Survey Outcomes

Across surveys and audits, one trend remains consistent:
If it isn’t documented clearly, timely, and consistently, surveyors will assume it didn’t happen.

Deficiencies are frequently tied to:

• Care plans not updated after significant changes
• Interventions not reflected in progress notes
• Incomplete incident investigations
• Breakdowns between CNA documentation, nursing notes, and MDS coding

Surveyors are looking for alignment across the medical record, interviews, and quality data.

 

Focus Areas for the New Year

Heading into the new year, facilities should expect:

• Continued focus on infection control, falls, abuse reporting, and MDS accuracy
• Increased scrutiny of documentation supporting quality measures
• Greater use of data to guide survey probes
• Less tolerance for delayed reporting or incomplete follow-up

Facilities that perform well are those that proactively audit their systems, strengthen interdisciplinary communication, and use quality data as a compliance tool — not just a reporting requirement.

 

Final Takeaway

The compliance trends of 2025 make one thing very clear: survey success is no longer about knowing the regulations — it’s about proving consistency, accuracy, and follow-through.

Facilities that invest time now on documentation accuracy, fall prevention systems, care plan integrity, and staff education will be far better positioned to manage surveys, audits, and enforcement actions in the year ahead.

If you’d like support reviewing your facility’s risk areas or preparing for upcoming surveys and audits, Proactive LTC Consulting is here to help.

 

Want to learn more?
Join us for our upcoming webinar, Regulatory Updates & Compliance Trends for the New Year, where we’ll break down the top deficiencies of 2025, emerging surveyor focus areas, and practical strategies facilities can use to proactively manage compliance risk.  Don’t miss this opportunity to get actionable insights, live Q&A, and practical strategies for survey readiness in 2026.

Kick start 2026 survey readiness by

• Scheduling a Proactive Mock Survey
• Adding an experienced Proactive Nurse Consultant to your team on an annual partner plan with a customized mix of remote and onsite services focused on clinical quality, compliance and reimbursement accuracy.

 

 

 

 

Written By:

 

Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, CPC, CLNC

Director of Regulatory Services

Proactive LTC Consulting