Welcome back to the Ftag of the Week on the CMSCG Blog, your go-to spotlight for decoding the regulatory landscape of skilled nursing and long-term care. Each week (or sometimes more) we break down a specific Ftag from the CMS State Operations Manual, offering practical insights, survey trends, and actionable guidance to help providers stay ahead of compliance challenges. The CMSCG Ftag of Week series is designed to sharpen your understanding, support quality improvement, and reinforce your commitment to resident-centered care.
If the title of this “Ftag of the Week” post is making you grimace, we hear you. However, F727 is one of those Ftags that was revised and effective at the end of April 2025, so let’s see what’s been added/ changed to ensure you know exactly what’s required.
Regulatory Revisions
Reference to the Social Security Act was added to F727, stating that related to required nursing care and facility waivers a nursing facility must use the services of a RN for at least 8 consecutive hours per day, 7 days a week (for services provided on or after 10/1/1990).
References added to this tag in SOM Appendix PP can be viewed here:
42 U.S.C. 1396r – Requirements for Nursing Facilities
42 U.S.C. 1395i-3 – Requirements for, and assuring quality of care in, skilled nursing facilities
What Else is Required
- Unless a waiver is approved, a nursing facility must designate an RN to serve as the Director of Nursing on a full-time basis.
“Full time” is defined as 40+ hours a week.
- The Director of Nursing is only allowed to serve as a charge nurse when the facility has an average daily census of 60 or fewer residents.
“Charge nurse” refers to a licensed nurse who has specific responsibilities that have been designated by the facility which include, but are not limited to, supervising staff, liaising with medical staff, acting as emergency coordinator and providing direct resident care.
A new definition which was also added to the revised Appendix PP is “scope of practice” which includes the services that a qualified health professional is deemed competent to perform and is permitted to undertake in keeping with his/her professional license terms.
Regulatory Guidance
- Nursing homes are responsible for ensuring that they have an RN providing services at least 8 consecutive hours a day, seven days a week – much like the title of the regulation indicates.
- The 8 consecutive hours may be met by one or more RNs.
- Hours worked by the Director of Nursing (DON) would be applicable to the 8 consecutive hour requirement.
During the survey entrance conference, confirmation that a full-time DON is employed will be addressed.
The Interpretive Guidance (IG) notes that based on the Facility Assessment, a facility may identify that it requires more than this minimum requirement for an RN based on the resident population’s acuity. Newly added guidance states that there are some responsibilities that only a Registered Nurse would be able to conduct which could not be delegated to another healthcare professional, and thus, this would change the amount of RN coverage needed.
Compliance Concerns
Surveyors will use the Sufficient and Competent Nurse Staffing Critical Element Pathway in addition to the guidance at F727 to determine compliance. The surveyors will also use the Payroll-Based Journal Staffing Data Report to identify noncompliance with this tag. Specifically, if no RN hours are reported in the PBJ Staffing Data Report, this will lead to noncompliance with F727.
Not sure you have the current Critical Element Pathways?
View and download the 7/30/2025 version here. You can always find the most recent survey resources information on the CMSCG website.
- If it is identified that there is an issue with the facility providing 8 consecutive hours of an RN onsite, the surveyors will notify the facility during the entrance conference The facility will be able to provide evidence that there was RN coverage despite PBJ data indicating otherwise.
- If the facility cannot provide acceptable evidence, then F727 will be cited at a minimum scope/severity of F (widespread), unless a waiver is in place.
That creates the potential for a domino-effect related to compliance, as the IG indicates that if surveyors can successfully link that a resident was harmed due to the facility’s failure to provide required RN services, then the deficiency at F727 could be cited at an actual harm level. The domino-effect occurs when there is a clinical care/services tag also cited directly related to RN staffing. Remember, there are certain tasks that only an RN is permitted to perform that an LPN/LVN cannot based on the State where the nurse is working, and these are the primary licensed staff in a nursing home.
Typically, we provide some interesting examples of actual survey citations for our “Ftag of the Week” posts, but a random sample of F727 citations in 2025 revealed a lot of facility staff indicating that the hours weren’t met because they couldn’t get coverage – and surveyors not changing their stance.
