11/26/2025

CMS Memo Addresses Survey and Certification Recovery

The Centers for Medicare & Medicaid Services has released a memo dated November 24 that responds to questions about survey and certification recovery following the federal government shutdown, which concluded November 12. Key points include:

• Survey and certification activities have fully resumed.
  CMS confirmed that all survey functions are back to normal without limitation.
  
• State survey agency funding is restored.
  Agencies will receive funding for the first quarter of FY 2026 and the first 30 days of the second quarter, aligned with FY 2024 levels.
  
• Additional funding supports hospice recertification surveys.
  The Continuing Resolution provides an extra $2 million for hospice recertification surveys required under the IMPACT Act through January 30, 2026.
  
• State licensure surveys conducted during the shutdown will not count as federal certification surveys.
  Federal certification surveys must still be completed, along with any lower-level complaint investigations handled under state authority during the lapse.
  
• Surveys that were underway when the shutdown began will resume.
  CMS clarified that providers do not need a new survey; however, survey teams may need to update samples and certain tasks.
  
• CMS-2567 deadlines apply for surveys with completed exits.
  If a survey team exited before the shutdown but had not issued the CMS-2567, the state survey agency must issue it by December 12.
  
• Exit dates may be adjusted.
  States may align the exit date with either:
  • the date the CMS-2567 is issued, or
  • the provider’s alleged compliance date,
  as long as compliance can be validated.
• Enforcement cycles may begin based on the adjusted exit date. This includes timelines for civil money penalties and Denials of Payment for New Admissions.