Since the Centers for Medicare & Medicaid Services (CMS) announced the nationwide rollout of the Risk-Based Survey (RBS), every administrator has been asking the same question: “Am I on the list?” Well, on Thursday, October 8, CMS finally gave us the data to give us some answers.
The Numbers
10.6%
That is the share of nursing homes that qualified in CMS’s preliminary June count: 1,560 of 14,682 nursing homes in the country. You may have seen “12%” listed in the QSO Memo. That figure is a simple average of the state percentages. Calculated from the counts, the share works out to roughly one building in ten.
11.6%
That is the share of facilities now carrying CMS’s new High Performing Icon on Nursing Home Compare – 1,699 facilities out of 14,690.
119
That is the number of completed surveys CMS has flagged as Risk-Based Surveys. 119 surveys across 12 states, as of mid-July. Most of the RBS trial occurred in four states – Ohio, Minnesota, Wisconsin and Pennsylvania.
Why Most Buildings Don’t Qualify
A facility has to clear all eleven of the criteria that CMS set out in its QSO Memo. Based on the most recent data refresh, the biggest barriers were:
- Overall rating below 5 stars: 79.5% of facilities (September data)
- Staffing rating below 3 stars: 39.0% (September data)
- Two or more residents 65+ with a schizophrenia diagnosis coded after admission: 19.5% (CMS’s June count)
- Actual-harm citation in the last survey cycle: 18.4% (September data)
- No standard survey in 18 months: 9.5% as of mid-August (1,403 facilities, from CMS’s QCOR system), essentially unchanged from 9.6% in CMS’s June count.
The reasons overlap, so many buildings trip more than one. Two of them deserve a second look. The schizophrenia-coding factor excludes roughly one facility in five, and it doesn’t appear in any public Care Compare file. The same is true of the two data audits, for staffing and for resident assessments. A building can look eligible on every public measure and still not be on the list.
Fun Fact – Same Size, Opposite Stories
Alabama and Maryland each have about 220 nursing homes. Their results could not be more different.
| Alabama | Maryland | |
| Nursing homes | 224 | 221 |
| Qualified for RBS (June) | 0 | 37 |
| Carry the High Performing Icon (Sept.) | 0 | 36 |
| Under 5 stars overall | 79.9% | 75.6% |
| Staffing under 3 stars | 12.9% | 30.3% |
| Actual-harm citation, last cycle | 3.1% | 11.8% |
| No standard survey in 18 months | 90.2% | 2.7% |
*Qualification is CMS’s June count. Ratings, citations and survey timing come from the September data, with survey dates through September 1.
On staffing and lack of high-level citations, Alabama’s buildings looked better than Maryland’s. But 202 of Alabama’s 224 facilities had gone more than 18 months without a standard survey, and that one criterion shut the entire state out. Maryland didn’t have the same backlog. Qualification isn’t only a measure of how your building performs. It also depends on where your State Agency is in its survey cycle.
What an RBS Looks Like So Far
We analyzed the data related to about 50 Risk-Based Surveys in Region V to see how things shaped up. Providers who received a RBS received an average of 2.3 citations each (among those with citations), compared with 7.8 for the region’s other standard surveys that produced citations. Infection control, particularly enhanced barrier precautions, was the most commonly cited issue. No surprises there. However, across all 119 surveys, 47 of them resulted in zero citations.
It’s not all sunshine and roses though. In Region V, three RBS citations were cited at an Actual Harm scope and severity, and one from a 2024 pilot survey was an IJ related to failure to investigate.
What to Do with This Info
- Know the criteria you can control – and review it routinely.
- Don’t treat the icon as the whole story – State Agencies conduct RBS surveys from the lists CMS gives them and their own knowledge of your building, not Nursing Home Compare.
- Be ready every day. Whether your next survey is an RBS or a full survey, the timing has never been harder to predict.
We are releasing the regional breakdown one CMS region at a time, with a snapshot for every state. These posts are free for healthcare providers to view with a RBS Insights account. Request free access to RBS Insights here. Accounts are reviewed.
Remember – eligibility is something you build. CMSCG helps organizations strengthen their survey readiness and systems – from mock surveys and targeted reviews to QAPI and ongoing, on-site support. Partner with CMSCG to improve your survey outcomes and your eligibility opportunity. Contact us to learn more.
