By Dr. Demetrius Kirk, DNP, RN, LNHA – CEO, SMK Medical

On October 1, 2025, the Centers for Medicare & Medicaid Services (CMS) issued QSO-26-01-ALL, outlining how survey and certification activities will be handled during a federal government shutdown. For long-term care leaders, this guidance has major implications.

At SMK Medical, we want to ensure you understand what changes, what continues, and how to protect your building during this period of uncertainty.

✅ What Continues During a Shutdown

Even with federal operations paused, CMS made it clear that resident safety remains a top priority. The following activities will continue in nursing homes and other LTC settings:

• Investigations of Immediate Jeopardy (IJ) or serious harm complaints
• Enforcement actions tied to IJ or actual harm (including remedies or terminations)
• Revisits required to prevent Medicare termination
• Emergency actions where resident life or safety is at risk

These functions are considered “essential,” and state survey agencies are required to carry them out despite the shutdown.

⏸️ What Stops During a Shutdown

While the essentials continue, most routine oversight is suspended until the government reopens. This includes:

• Annual recertification surveys for nursing homes
• Most revisits (unless tied to termination timelines)
• Initial Medicare certifications for new facilities or ownership changes
• Lower-level complaint investigations (below IJ/harm level)
• MDS activities tied to survey functions (reporting continues, but survey-related use is paused)
• Informal Dispute Resolutions (IDRs) not tied to immediate enforcement actions

⚠️ The Impact for LTC Operators

For many leaders, the initial reaction may be relief—fewer surveyors walking in the door. But the reality is more complex:

• IJ cases are still fully investigated. If your building faces a serious complaint, the shutdown will not shield you.
• Enforcement remains active. Terminations and penalties tied to serious harm will still move forward.
• Backlogs will grow. When the shutdown ends, surveyors will return with urgency to catch up, increasing the risk of stacked citations.
• State licensure oversight remains. Shutdown or not, states can still act under their own laws.

💡 Why Facilities Need SMK Medical Now

Survey readiness is not something to pause just because CMS is slowing down. In fact, this is the best time to prepare. At SMK Medical, we help facilities stay ahead of compliance risk with:

• 🔍 Mock Surveys that uncover deficiencies before surveyors arrive
• 📝 MDS & PDPM Support to protect reimbursement and accuracy
• 📊 QAPI Program Development & Training built for CMS compliance
• 🚑 Immediate IJ Removal Support when timing is critical
• 👥 Leadership Training & Development to strengthen your team’s response

Routine oversight may slow down, but risk doesn’t. Facilities that prepare now will avoid costly enforcement later.

📞 Take Action Today

Don’t wait for surveyors to catch you unprepared after the shutdown. Partner with SMK Medical to stay compliant, protect your residents, and safeguard your revenue.

📱 Call us today at 313-314-8267 or visit SMKMed.com to schedule a consultation.

Disclaimer

The content provided on this blog by SMK Medical is for general informational purposes only and is specifically tailored to post-acute care executives, leaders, and directors. The information, including regulatory compliance guidance, reflects our understanding at the time of publication. Rules, regulations, and standards in the healthcare industry are subject to frequent change, and SMK Medical makes no representations or warranties regarding the completeness or current accuracy of the content provided. All case examples or scenarios mentioned have been anonymized and/or aggregated to protect the identity of the parties involved. This blog does not constitute professional advice, consultation services, or establish a client relationship. Readers are strongly encouraged to consult with qualified professionals and verify current regulations before making any decisions based on the information presented. SMK Medical expressly disclaims any and all liability for any direct, indirect, or consequential damages resulting from the use of or reliance on this content.