CMS Could Improve Oversight of States’ Use of Contract Surveyors for Nursing Home Surveys
Learn how the AI-generated research projects were createdOverall Conclusion
CMS did not provide adequate oversight of States’ use of contract surveyors to conduct nursing home surveys, increasing the risk that contract surveyors do not meet Federal requirements; CMS concurred with the recommendations.
Source Document
Audit Scope
Audit period October 1, 2022, through July 30, 2025. Nonstatistical sample of 14 State Agencies that used contract surveyors to perform nursing home surveys. Reviewed CMS contracts with third-party contractors for Federal Monitoring Surveys (FMSs) for FY 2023. Assessed whether contract surveyors met Federal requirements and the effectiveness of CMS and SA oversight, including data reporting and monitoring practices.
Key Findings Summary
CMS did not provide adequate oversight of States’ use of contract surveyors to conduct nursing home surveys.
A nonstatistical sample of 14 States that used contract surveyors found that all could improve their policies and procedures to ensure CMS guidelines were met.
During the audit period, CMS issued the April 2024 SA Memo outlining contracting practices that SAs could use to ensure contract surveyors meet Federal requirements, but CMS did not monitor whether SAs implemented practices that achieved the memo’s underlying objectives.
View the Findings tab to see all 6 findings
AI-Assisted
AI Scope Summary
Building on CMS oversight objectives, future MedicaidSA audits should evaluate how well CMS and State Survey Agencies implement the 2024 SA Memo, with a focus on monitoring and reporting contractor involvement, including how iQIES fields capture worker classification and how annual SA assessments verify compliance.
AI-Generated Insight
The audit identifies governance and data-reporting gaps in the use of contract surveyors for critical nursing home surveys, highlighting the transition to iQIES as an opportunity to implement standardized contractor-status reporting and stronger internal controls.
Audit Objectives
Determine whether CMS provided adequate oversight of States’ use of contract surveyors to conduct nursing home surveys.
Audit Findings (6)
CMS did not provide adequate oversight of States’ use of contract surveyors to conduct nursing home surveys.
A nonstatistical sample of 14 States that used contract surveyors found that all could improve their policies and procedures to ensure CMS guidelines were met.
During the audit period, CMS issued the April 2024 SA Memo outlining contracting practices that SAs could use to ensure contract surveyors meet Federal requirements, but CMS did not monitor whether SAs implemented practices that achieved the memo’s underlying objectives.
CMS did not monitor SA use of contract surveyors as part of its annual assessment of SAs and did not track which States used contract surveyors.
CMS lacked staff and resources to perform this function.
CMS could improve documentation and reporting on contract surveyors and by implementing protocols requiring SA and CMS surveyors to specify in iQIES whether any survey team member is a contract surveyor.
Recommendations (2)
Add worker classification (i.e., employee or contractor) as a required entry in iQIES and require CMS and SAs to record the status of each individual performing any nursing home survey (including an FMS).
Confirm that SAs have policies and procedures in place to ensure that contract surveyors performing nursing home surveys meet Federal requirements, e.g., verify during the annual assessment of SAs.