The Centers for Medicare & Medicaid Services (CMS) issued a new QSO Memo on November 24, 2025 for all provider types, “Questions + Answers for State Recovery after the Federal Government Shutdown.” The document includes answers to the questions CMS received from providers and State Agencies regarding survey & certification activities during the shutdown.
Key points:
- All survey, enforcement and certification activities should be conducted. Any activities which were suspended as part of the shutdown should be resumed.
- Deficiencies which were identified as part of the federal survey process during the shutdown will be considered federal citations.
- A CMS-2567 should be issued for all federal surveys which were held due to the shutdown by December 12, 2025. This should only affect lower-level deficiencies since harm and IJ survey activities continued during the shutdown.
- Any survey which was in progress when the shutdown occurred should be completed. A new survey will not be started.
- For surveys where there were low-level or no deficiencies that were held during the shutdown, a 2567 should be issued by December 12, 2025. The exit date should be adjusted to be the date the 2567 is issued to the provider or the date of compliance that the provider achieved compliance and this was verified by the state.
- Regarding enforcements, the enforcement cycle begins with the survey exit date with the exception of CMPs and State monitoring. The effective dates of those remedies can’t be any earlier than when advance notice is provided.
Read the full Q&A Memo here.
Need assistance with a plan of correction or other survey-related concern? Contact CMS Compliance Group, Inc. to discuss or learn more about our services.
