US
Centers for Medicare and Medicaid Services
Published September 2, 2026

CMS Could Improve Oversight of States' Use of Contract Surveyors for Nursing Home Surveys

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Overall Conclusion

CMS did not provide adequate oversight of State survey agencies’ use of contract surveyors to conduct nursing home surveys, increasing the risk that Federal requirements are not consistently met.

Source Document

Audit Scope

Review of CMS oversight over State survey agencies' use of contract surveyors to conduct nursing home surveys, focusing on Federal requirements and related memorandum; the exact audit period is not specified in the provided text.

Key Findings Summary

1

CMS did not provide adequate oversight of States’ use of contract surveyors to conduct nursing home surveys.

2

During our audit period, CMS issued a memo to SAs outlining contracting practices SAs could use to ensure that contract surveyors meet Federal requirements, but CMS did not monitor whether SAs implemented practices that achieved the memo’s underlying objectives.

3

Our survey of 14 States that used contract surveyors found that all 14 could have improved their policies and procedures to ensure that the CMS guidelines were met.

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AI-Assisted

Generated by gpt-5-nano

AI Scope Summary

The audit aims to determine whether CMS adequately oversees State survey agencies’ use of contract surveyors for nursing home surveys and to assess the sufficiency of CMS monitoring and SA policies; future audits should examine the effectiveness of the recommended changes (worker classification in iQIES, SA policy verification) and track improvements in compliance.

AI-Generated Insight

The audit identifies a governance gap in CMS oversight of the use of contract surveyors by State survey agencies. It notes no monitoring of the memo’s implementation and calls for enhancements to data collection in iQIES and formal SA policy verification to close the oversight gap and improve nursing home survey quality.

Audit Objectives

1

Assess whether CMS adequately oversees State survey agencies’ use of contract surveyors to conduct nursing home surveys in accordance with Federal requirements.

Audit Findings (4)

1

CMS did not provide adequate oversight of States’ use of contract surveyors to conduct nursing home surveys.

2

During our audit period, CMS issued a memo to SAs outlining contracting practices SAs could use to ensure that contract surveyors meet Federal requirements, but CMS did not monitor whether SAs implemented practices that achieved the memo’s underlying objectives.

3

Our survey of 14 States that used contract surveyors found that all 14 could have improved their policies and procedures to ensure that the CMS guidelines were met.

4

In the absence of CMS monitoring and oversight, there is an increased risk that SAs have not implemented sufficient controls to ensure that contract surveyors meet Federal requirements when performing nursing home surveys.

Recommendations (2)

1

Add worker classification (i.e., employee or contract surveyor) as a required entry in CMS's quality improvement and evaluation system (iQIES) and require CMS and SAs to record the status of each individual performing any nursing home survey (including an FMS).

2

Confirm that SAs have policies and procedures in place to ensure that contract surveyors performing nursing home surveys meet Federal requirements; CMS could verify these policies and procedures during its annual assessment of SAs.