CMS Long-Term Care Survey Changes & Nursing Home Oversight

What Changes to CMS Long-Term Care Surveys Mean for Nursing Home Oversight

In April 2025, the Centers for Medicare & Medicaid Services (CMS) implemented sweeping changes to its Long-Term Care (LTC) surveyor guidance, signaling a stronger commitment to improving the quality of care in nursing homes. These updates modernize oversight procedures and place increased accountability on providers to safeguard resident rights and well-being and ensuring better accountability for nursing home residents.

CMS Long Term Care Updates

One of the most significant updates involves the consolidation and clarification of rules surrounding resident transfers and discharges. By creating clearer guidance under new F-Tags F627 and F628, CMS aims to prevent inappropriate discharges and protect residents from being removed unfairly. Facilities can no longer include third-party payment guarantees in admission agreements, helping reduce financial exploitation.

CMS also restructured guidance on psychotropic medications, placing new emphasis on residents’ rights to refuse or accept treatments. The updated F605 tag reinforces the importance of informed consent and ensures that medications are not used as chemical restraints for staff convenience.

Medical directors are now held to higher standards, with expanded responsibilities that include active participation in policy enforcement and quality assurance. This shift encourages stronger clinical leadership and better adherence to care protocols.

For nursing homes, the implications are clear: oversight will be more rigorous, and noncompliance may carry greater consequences. Facilities must reassess their internal policies, retrain staff, and prepare for more detailed inspections.

CMS’s revised guidance marks a pivotal moment in long-term care regulation, placing residents at the center of care. These changes aim to enhance the quality and oversight of nursing home care by updating regulatory standards, consolidating guidance, and reinforcing resident protections.

Key Updates to the CMS Long-Term Care (LTC)

1. Admission, Transfer, and Discharge:
   • CMS has consolidated several F-Tags related to resident transfers and discharges into two new tags: F627 (Inappropriate Transfers and Discharges) and F628 (Transfer and Discharge Process).
   • Facilities are now prohibited from including language in admission agreements that requests or requires a third-party guarantee of payment, ensuring residents are not unfairly burdened.
2. Use of Psychotropic Medications:
   • Guidance for unnecessary psychotropic medication use (formerly under F758) has been consolidated into F605, emphasizing residents’ rights to be free from chemical restraints used for staff convenience.
   • Facilities must ensure residents are fully informed and able to participate in decisions about their treatment, including the right to accept or refuse psychotropic medications.
3. Medical Director Responsibilities:
   • The role of the medical director has been expanded to include active participation in implementing resident care policies, ensuring physician compliance with facility policies, and involvement in quality assessment and assurance activities.
4. Minimum Data Set (MDS) Accuracy:
   • CMS has updated guidance to ensure the accuracy of MDS assessments, particularly concerning antipsychotic medication prescriptions.
   • Surveyors are now instructed to refer cases to the Office of Inspector General if patterns of inaccurate MDS coding are identified.
5. Infection Prevention and Control:
   • New guidelines incorporate enhanced barrier precautions to prevent the spread of multidrug-resistant organisms, aligning with recent CMS memos.
6. Pain Management and CPR:
   • Revisions align pain management guidance with CDC definitions, emphasizing individualized opioid treatment plans.
   • CPR certification standards have been updated to align with nationally accepted standards.

Why Did CMS Need to Update Nursing Home Oversight?

CMS updated its nursing home oversight to address longstanding issues in care quality, resident safety, and regulatory enforcement that have been highlighted by both data and public concern in recent years. Several key reasons drove the need for these updates:

1. Persistent Quality of Care Concerns

Despite previous reforms, many nursing homes continued to struggle with issues such as understaffing, inappropriate use of medications (especially antipsychotics), and unsafe discharges. CMS recognized that existing rules lacked the clarity and enforcement strength needed to ensure consistent, high-quality care to help avoid concerns like nursing home abuse and neglect.

2. Resident Rights and Protections

There was a growing need to strengthen protections for residents—particularly around involuntary discharges, chemical restraints, and informed consent for treatment. The updates reinforce residents’ rights to autonomy, dignity, and safe living conditions.

3. Accountability and Transparency

CMS aimed to increase provider accountability by improving the accuracy of clinical documentation (like MDS assessments) and making facility leadership, including medical directors, more responsible for care outcomes. This also aligns with broader goals of transparency in healthcare.

4. Public and Government Pressure

Following the COVID-19 pandemic and subsequent investigations, public and legislative scrutiny intensified. Stakeholders demanded better oversight and systemic changes to prevent neglect and protect vulnerable populations.

In short, the updates were necessary to modernize oversight, close regulatory gaps, and ensure nursing homes meet evolving standards of safety, ethics, and person-centered care.

Implications for Nursing Homes

The recent updates to the Centers for Medicare & Medicaid Services (CMS) Long-Term Care surveyor guidance, effective April 2025, mark a significant shift in nursing home oversight. These changes tighten regulatory expectations and expand surveyor responsibilities, with the ultimate goal of improving resident care and safety.

Facilities can expect increased scrutiny in several areas, including discharge practices, medication use, infection control, and documentation accuracy. For example, updated guidance now prohibits facilities from including third-party payment guarantees in admission agreements, ensuring residents are not unfairly burdened. Additionally, new rules demand greater accountability in the use of psychotropic medications, with a stronger focus on informed consent and resident autonomy.

Medical directors now play a more active role in oversight, including policy enforcement and quality assurance activities. Surveyors will also monitor Minimum Data Set (MDS) accuracy more closely, with patterns of misreporting flagged for federal investigation.

These updates mean that nursing homes must proactively adjust internal policies, train staff on the new standards, and prepare for more comprehensive inspections. Failure to comply could result in increased citations or even funding repercussions. Overall, the revised CMS guidance represents a renewed emphasis on transparency, resident rights, and consistent quality care across long-term care facilities.

These comprehensive updates reflect CMS’s commitment to improving resident care quality and safety in nursing homes. Facilities are expected to review and adjust their policies, procedures, and training programs to comply with the new guidance. Surveyors will utilize the revised standards to assess compliance, which may lead to increased scrutiny in areas such as medication management, discharge practices, and infection control.

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References

CMS (2025). “REVISED: Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process.” https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-and-cms-locations/revised-revised-long-term-care-ltc-surveyor-guidance-significant-revisions-enhance-quality-and-0

Bohler, F., & Adashi, E. Y. (2025). Staffing Up: The Nursing Home Minimum Staffing Rule. Journal of General Internal Medicine, 1-2.

“Navigating the 2025 CMS Updates: Key Changes for Long-Term Care Facilities” (2025). https://constellationqualityhealth.org/navigating-the-2025-cms-updates-key-changes-for-long-term-care-facilities/

paltmed.org

“Major CMS Revisions to Nursing Home Surveyor Guidance: What Owners Need to Know for 2025” https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-and-cms-locations/revised-revised-long-term-care-ltc-surveyor-guidance-significant-revisions-enhance-quality-and-0