Another week, another revised “Ftag of the Week” to address the new LTC surveyor guidance effective March 25, 2025. In case you missed this post on the CMSCG Blog, on January 15, 2025, the Centers for Medicare and Medicaid Services (CMS) revised its November 18, 2024 QSO Memo which addressed the “significant revisions” to the LTC survey process. The revised QSO Memo includes revisions to several tags, including F725 Sufficient Nurse Staffing. Let’s look at what’s been revised.

View CMSCG’s August 2022 “Ftag of the Week” for F725 here. We discuss key points from the reg, so don’t miss out by just reading the revision.
Definitions
For F725, there is no change to the regulation itself, but there are several new definitions which have been added.
“Licensed Nurse” – Any nurse that requires the successful completion of a National Council Licensure Examination (NCLEX-PN or NCLEX-RN). At a minimum, this would include a Licensed Practical Nurse (LPN) or a Registered Nurse (RN). Licenses and titles are defined and protected by a the Nurse Practice Act (NPA) for usage in the public. They are privileged and granted by the Board of Nursing (BON) after meeting the requirements of graduating from accredited nursing educational programs, passing professional board examinations, background checks and paying applicable fees.
“Charge Nurse” – A licensed nurse with specific responsibilities designated by the facility that may include staff supervision, emergency coordinator, physician liaison, as well as direct resident care.
“Scope of Practice” – Services that a qualified health professional is deemed competent to perform and permitted to undertake, in keeping with the terms of their professional license.
What’s in the Revised Guidance
Portions of the revised guidance to surveyors reflect some of the other regulatory requirements, such as:
- Facility must provide licensed nursing staff 24/7, along with other nursing staff
- Facility must designate a licensed nurse to serve as a charge nurse for each shift
The new guidance also states that there are several areas that can offer insight into potential insufficient staffing, which surveyors are expected to discuss and investigate. These areas, not surprisingly, include:
- Falls
- Weight loss
- Dehydration
- Pressure ulcers
- Elopement
- Resident altercations
Compliance Considerations
There are two pieces of guidance which factor into where staffing issues should be cited.
First, F725 should not be cited related to State staffing requirements, since this tag is meant to determine compliance with Federal staffing standards. The Federal standards require that facilities provide sufficient staff to meet all of the residents’ basic and individualized needs. Concerns related to not meeting State staffing requirements will be cited under F836 Administration.
The guidance states that F725 may only be cited if noncompliance has been identified related to:
- Not providing services by a sufficient number of nursing staff (licensed and non-licensed)
- Not providing licensed nursing staff 24/7
- Not having have a licensed charge nurse on each shift
Added Emphasis on the Payroll-Based Journal (PBJ)
The revised guidance also includes much more information on how surveyors should use the Payroll-Based Journal data available for a provider as part of their off-site preparation. Some of the guidance is from the LTCSP Procedure Guide, but now it’s included in the SOM as well for surveyor reference. CMS now states in the revisions that the PBJ Staffing Data Report is available to surveyors and must be used for every recertification survey, at a minimum. The PBJ Report provides insight into compliance with several Ftags, so depending on what’s in the report, some citations could be evident right off the bat. Those include:
- F725 Sufficient Nurse Staffing – if the facility did not have licensed nurse coverage in the facility 24/7 and/or reported excessively low weekend staffing and/or has a one-star Staffing rating
- F727 RN 8 Hrs./7 days/Wk., Full Time DON – if the facility has reported no RN hours to the PBJ
- F851 Payroll-Based Journal – If the facility did not submit its PBJ data for the quarter
We’ll dig into the Investigative Procedures and how it’s linked to the PBJ Report in Part 2 of this revised Ftag of the Week.

CMS Compliance Group, Inc. is a regulatory compliance and quality improvement consulting firm. CMSCG provides consulting assistance to post-acute providers including nursing homes, home health agencies, assisted living and other providers. Contact us to learn more.
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