June 4, 2026

Risk-Based “Short” Survey Pilot Brings Shorter Review Option for Nursing Homes

On June 4, 2026 by Mark Schulz

CMS continues to test a risk-based survey process known as a “short survey” for select nursing homes that meet higher-quality indicators. The shorter survey approach is intended to focus survey resources while still protecting resident health and safety. The short survey still meets CMS requirements for the standard survey cycle.

What CMS is Testing

In April 2024, CMS shared more details about the risk-based process stating that it may apply to nursing homes that consistently show higher-quality performance. Examples may include fewer citations, no recent harm or abuse citations, no pending immediate jeopardy investigations, higher staffing, fewer hospitalizations and compliance with staffing and data reporting requirements.

Minnesota was selected to participate in the initial risk-based survey pilot for nursing home standard recertification surveys. The early phase of testing helped CMS and state survey agencies evaluate whether a shorter, more focused review could still assess compliance with federal health and safety requirements.

In its most recent mission and priorities materials, CMS said it continues to test the risk-based survey approach and will identify next steps after testing is complete. Minnesota’s recent member experiences with the risk-based survey suggest the evaluation of the short survey is in an active phase of testing in the state with members early feedback being very positive.

Standard Survey Requirement

The short survey is not a complaint survey or an optional review. It is conducted as the facility’s standard recertification survey but only under the CMS risk-based survey process. That means the short survey satisfies the federal requirement that each nursing facility receive a standard survey no later than 15 months after the last standard survey. If surveyors identify concerns during the short survey, their review can expand into a typical standard survey. Members should continue to treat the process as a standard survey and remain prepared for a broader review if findings warrant it.

MDH Information

During the most recent Minnesota Department of Health meeting, MDH reported that for the period between Jan. 1 and May 2026, 16 short surveys had been conducted in Minnesota. Of those, eight were deficiency free, with the remaining having minimal deficiencies or at very low levels. Members who interacted with MDH surveyors during the process reported a very positive and pleasant experience. The day after the MDH meeting, another member shared that they also received a short survey and reported the same positive experience.

What this Means for Members

LeadingAge Minnesota will continue to monitor CMS and MDH updates on the risk-based survey process. Nursing home members should continue to focus on survey readiness, strong documentation, quality outcomes and compliance with current federal and state requirements.