CMS Risk-Based Survey qualifying criteria: the 11 checks, explained for operators

Eleven checks, every quarter, all at once. That’s what stands between a 5-star nursing home and the High Performing Facility icon on Care Compare, and the checks live in Appendix A of CMS memo QSO-26-14-NH, dated July 16, 2026.

Here’s each one in operator language, which ones trip strong buildings, and the 5 disqualifiers in Appendix C that can convert your short survey back into a full one.

What the Risk-Based Survey is

The RBS is a modified version of the standard recertification survey, reserved for facilities with a clean record. CMS describes it as a shorter review of all the required areas with fewer activities, “conducted in roughly half the time with fewer total surveyors.” A smaller resident sample, the same regulatory ground.

It went national on September 8, 2026. CMS’s stated reason is capacity: state agencies can’t hire enough surveyors, complaint investigations are backing up, and a shorter survey at low-risk buildings frees hours for high-risk ones. Facilities that qualify get the trophy icon on Care Compare, and the public list posts to the Provider Data Catalog beginning September 30.

One caveat before the list. States can still run a full survey at a qualifying facility if complaints or other concerns warrant it, and CMS can require one. The icon earns you a shorter default survey. States keep the option of a full one.

The 11 checks

Appendix A is written as 11 things a facility must not have. Grouped by what controls them:

Ratings (checks 1, 2, 8)

1. Less than a 5-star overall rating. The entry ticket.

2. Less than a 3-star staffing rating. A 5-star overall building can carry a 2-star staffing rating and miss here. Staffing is the check most directly tied to recruiting and retention.

8. A health inspection score above the 50th percentile in your state. Lower is better. This one is relative: your score is measured against every other building in your state, so a mediocre survey year in a strong state costs more than the same year elsewhere.

Survey record (checks 3, 4, 11)

3. Any actual harm, immediate jeopardy, or substandard quality of care citation in the last survey cycle. Cycle means the last standard survey plus any complaint investigations in the past year. One G-level tag on a complaint visit is enough.

4. More than 18 months since your last standard survey. Largely out of your hands, and given state backlogs, this will keep many strong buildings off the first lists. If you’re at month 17, you can’t fix it. You can know it.

11. Special Focus Facility candidate status. Self-explanatory.

Data integrity (checks 6, 7)

6. A failed Payroll-Based Journal staffing audit. CMS audits the hours you submit. If they can’t verify them, you fail, and you’re out regardless of the staffing star.

7. A failed MDS audit. Same logic for resident assessment data.

Waivers, coding, ownership (checks 5, 9, 10)

5. Any staffing waiver in effect under 42 CFR 483.35.

9. Two or more residents 65 or older coded with schizophrenia after admission without the diagnosis. This is the antipsychotic-coding check, and it’s a bright line: 2 residents.

10. A change in ownership since the last standard survey. New owners wait for the next full survey. Acquisitive networks will feel this one across the portfolio.

The 5 disqualifiers

Making the quarterly list is step one. Appendix C lists 5 things that pull a listed facility off before the RBS starts and convert it to a standard survey:

1. A harm, immediate jeopardy, abuse, or substandard quality of care citation on an intake investigation while listed.
2. A pending intake investigation triaged at immediate jeopardy.
3. More than 3 pending non-IJ intakes triaged medium or higher.
4. CMS-approved nursing waivers.
5. A change in ownership since the last standard survey.

Item 3 is the quiet one. Four open medium-severity complaints, none substantiated, is enough to lose the short survey. Complaint volume tracks family communication more than clinical quality, which makes it one of the few checks marketing has a direct hand in.

The checks that trip strong buildings

From the list above, 4 stand out as the ones a well-run, 5-star facility can miss:

• The 18-month clock (check 4). Survey backlogs are the state’s problem and your disqualifier.
• The state median (check 8). A relative bar moves when your neighbors improve.
• Ownership change (check 10). Every acquisition resets the clock on that building.
• Open complaints (Appendix C, item 3). Volume alone.

What an operator can actually move

Three of the checks respond to work you control this quarter.

Staffing (check 2) responds to recruiting and retention, and the buildings that recruit well have a brand people want to work for. The Staff Culture class in the MOZART&CO. Academy covers the recognition systems behind that, and Prestige Healthcare is what it looks like when 16 facilities recruit under one identity.

Complaint volume (Appendix C, item 3) responds to how families hear from you before they’re angry. A family communications framework is an operations tool with a survey payoff.

Coding (check 9) responds to clinical governance, and it’s the one to audit today, because 2 is a small number.

The rest is survey performance and time.

The quarterly checklist

Before each list posts, someone at each building confirms: overall stars, staffing stars, inspection percentile, last standard survey date, open intakes and their triage levels, PBJ and MDS audit status, waivers, ownership date, and the schizophrenia coding count. Fifteen minutes per building. It tells you whether the trophy is coming, and it’s the same data your removal plan needs.

If the trophy is coming, the first 7 days are already written. And when it’s time to put it in front of families and referral partners across every building that qualified, that’s the recognition campaign we run at MOZART&CO. Inquire when you know your count.