On November 24, 2025, CMS released FAQs for state survey agencies following the federal government shutdown from October 1 to November 12, 2025. The FAQs include information on the resumption of survey activities, and survey findings and enforcement actions. Highlights of the FAQ can be found below:
Resumption of Activities
- States are authorized to resume all survey, enforcement, and certification activities that were suspended during the shutdown.
- State licensure surveys completed during the shutdown must be repeated federally if they do not align with federal Medicare/Medicaid standards.
- States should issue all held CMS-2567 forms by December 12, 2025, and may adjust exit dates to reflect compliance dates verified by the state.
Survey Findings and Enforcement Actions
- Deficiencies identified during the shutdown will be considered federal citations if they pertain to non-compliance with federal requirements.
- States may continue surveys that were in progress during the shutdown without starting over, but may need to update certain information such as the sample of patients/residents or include intervening complaint issues.
- Enforcement actions and timelines will be calculated based on the survey exit date, with specific advance notice requirements for sanctions.