Starting September 8, 2026, CMS is rolling out its Risk-Based Survey (RBS) program nationwide for nursing homes and skilled nursing facilities.*
In plain terms: Roughly 12% of nursing homes will qualify for a streamlined survey, one that takes half the time, requires fewer surveyors and signals publicly that your facility is a high performer. CMS will display a “high performer” icon on Nursing Home Care Compare and publish the qualifying list on September 30.*
The other 88% receive the standard survey, or a more intensive one.
Which group your facility lands in depends heavily on what you built before the surveyor walked in the door.
What CMS is looking at.
Eligibility for the Risk-Based Survey isn’t a single metric. CMS built the criteria around a combination of factors:
What ties most of these together: documentation, training accountability and policy compliance. A facility with current, accessible policies and evidence that staff are following them is a facility with fewer citations, better outcomes and a stronger star rating.
Your policy program isn’t a back-office function. It’s a direct input into whether you qualify for a shorter, less disruptive survey.
Most nursing homes have policies. What they often don’t have is a policy program: a system that ensures policies are current, staff have read and understood them, and changes are tracked and documented.
When surveyors arrive, they’re not just looking for binders. They’re asking:
A signature on a sign-in sheet doesn’t answer those questions. But, a quiz score does. A version-controlled approval workflow with an audit trail does. And a regulatory alert system that links changes directly to affected policies does.
The facilities that consistently land fewer citations and are best positioned to qualify for the RBS tend to share a few things.
They don’t rely on staff to find the right policy on their own. Policies live in one searchable, always-current system. There’s no question about which version is active, and no one is working from a binder that hasn’t been updated since last year.
They have evidence that staff understood the policy, not just that they saw it. Competency quizzes and configurable attestations give compliance officers documentation that holds up when a surveyor asks.
They know about regulatory changes before a surveyor tells them. Whether it’s a CMS update to the Requirements for Participation or a state-level change, high-performing facilities have a system that monitors regulations and flags which policies are affected, before the survey window opens.
Their policy review process doesn’t restart from scratch when someone rejects a draft. Step-specific rejection means a single reviewer’s feedback doesn’t send a policy back to square one. Review cycles that used to take months get completed on time.
Your policy program is being evaluated whether you know it or not.
The Risk-Based Survey program formalizes something that has always been true: CMS is assessing your compliance posture continuously, not just during survey windows. Your citation history, your star rating and your staffing data all feed a risk score that determines how much scrutiny you’re under.
The facilities that will qualify for the September 2026 RBS didn’t prepare in August. They built systems that produce clean documentation, current policies and trained staff consistently, and that track record shows up in the data.
If your policy program isn’t giving you confidence going into survey season, that’s not a documentation problem. It’s a systems problem.
Ntracts Policy Manager gives nursing homes and health systems one searchable, always-current home for every policy, with 15,000+ professionally developed, customizable templates written by on-staff registered nurses to current regulatory and accreditation standards, automated regulatory monitoring, step-specific approval workflows and built-in attestation and competency tracking.
Download the Policy Management Evaluation Toolkit
*CMS Compliance Group: CMS Makes It Official: Risk-Based Surveys Are Going Nationwide September 8 (cmscompliancegroup.com); LeadingAge: CMS National Nursing Home Risk-Based Survey Approach Begins September 2026 (leadingage.org); McKnight’s Long-Term Care News: CMS Risk-Based Surveys to Debut Nationally in September (mcknights.com)