On October 21, 2025, CMS released REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown guidance. Key Updates from the memo include:
- Revisits to Prevent DPNA: States may now conduct revisits to prevent a three-month denial of payment for new admissions (DPNA).
- Pending CMS-2567s: Completed surveys not fitting excepted categories and lacking a CMS-2567 should be held; they remain valid post-shutdown, with CMS to issue further guidance.
- Standard Surveys: Processing of surveys without immediate jeopardy or harm findings must be paused.
- Authorized Revisits: Only revisits to prevent termination of Medicare participation within the 45 days, verify correction of immediate jeopardy or harm, or prevent a denial of payment for new admissions within 15 days are allowed.
- Initial Surveys/Certifications: No Medicare initial surveys or certification actions may occur, except as allowed (e.g., Medicaid-only upon state consultation).
- Complaint Investigations: Only those alleging immediate jeopardy or actual harm should proceed.
- State-Funded Surveys: May continue but will not count as federal surveys.
- Facility Closures: States must ensure safe resident relocation for voluntary nursing home closures.
- Provider Enrollment: All enrollment and change of ownership related surveys are suspended.
- Contractor Work: Federal contractors may not perform non-excepted activities.