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CMS just released QSO-26-02, and every post-acute care leader should understand the impact. This memo explains how states must recover from the federal shutdown that stalled surveys from October 1 through November 12.
Here is the fast, practical summary.
1. Survey Activity Is Restarting Immediately
CMS lifted all restrictions. States must resume full survey and enforcement operations at once.
2. State-Only Surveys Must Be Repeated Federally
If your building was surveyed under state licensure during the shutdown, that same survey must now be repeated under federal requirements.
CMS was clear, there is no crosswalk between state standards and federal tags.
3. All Held CMS-2567s Must Be Issued by December 12
States can adjust exit or compliance dates as long as they validate the correction. Expect a wave of delayed 2567s to hit inboxes soon.
4. Shutdown Citations Still Count
Anything cited by federally qualified surveyors during the shutdown still stands. Nothing was erased.
5. Backlog Will Trigger Faster Survey Cycles
Complaint entries must be re-entered in iQIES, enforcement clocks did not pause, and states must catch up quickly.
Facilities should expect faster-than-normal survey activity.
Why This Matters for Operators
This memo signals a sharp increase in survey volume. Buildings that are not ready will feel the impact, especially with repeated surveys, delayed 2567s, and tighter enforcement timelines.
Now is the time to tighten systems, correct issues, and validate your compliance.
The Advantage of MockSurvey.com
Do not wait for a federal surveyor to show you your blind spots.
MockSurvey.com delivers the complete survey-readiness assessment operators need right now, including:
Many companies imitate mock surveys. There is only one MockSurvey.com, backed by real clinicians, administrators, and regulatory experts.
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SurveyGuard: Your Digital Compliance Backbone
SMK Medical’s upcoming platform, SurveyGuard, is designed to keep buildings survey-ready even during rapid regulatory shifts.
Modules include:
SurveyGuard supports real-time tracking, documentation, and AI-driven insights, helping operators stay ahead in an unpredictable survey cycle.
Prepare Before Surveyors Return
QSO-26-02 is clear , CMS expects states to recover immediately, and that means survey teams will be moving fast.
Strengthen your readiness now.
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.
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