CMS issues Revisions to SOM Chapter 5 and SOM Chapter 7

Hot off the presses — In a new QSO Memo dated February 2, 2026 (despite today being January 30, 2026), the Centers for Medicare & Medicaid Services (CMS) issued updated guidance. The Memo, “Revisions to State Operations Manual (SOM) Chapters 5 and 7” addresses guidance for Chapter 5 related to Immediate Jeopardy and Chapter 7 regarding a plethora of survey-related items. Guidance from Appendix P was moved to Chapter 7.

Memorandum Summary

CMS is releasing the following guidance in Chapter 5 of the SOM:

  • Revisions to Immediate Jeopardy Priority Definition examples for Nursing Homes; and
  • Clarification of Off-site investigations.

CMS has updated and revised guidance in Chapter 7 of the SOM that includes:

  • Survey Team Composition, Survey Procedures, Plans of Correction, Verifying Corrections, Survey Revisit and Offsite Revisit Paper Review, Off-hours Survey, Enforcement, Nurse Staffing Waivers, Disposition of Civil Money Penalties (CMP), Federal Civil Penalties Inflation Reduction Act, Informal Dispute Resolution (IDR), and Independent Informal Dispute Resolution (IIDR);
  • Additionally, guidance previously found in Appendix P of the State Operations Manual has been added to Chapter 7; and
  • Technical changes that include updates for accurate references.

These changes are effective March 30, 2026. View the revisions in QSO-26-03-NH here and check back shortly to the CMSCG Blog for key information.  Want to receive updates direct to your inbox? Register here.

In the meantime, check out our thoughts in this McKnight’s LTC News article for more information: Up next for nursing home surveys: more after-hours inspections, consistent team staffing


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