Evidence record

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

Audit organization
Office of Inspector General, U.S. Department of Health and Human Services
Publication date
September 2026
Source record
Metadata record

Findings

6

Recommendations

2

Overall 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.

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.

Findings (6)

Each finding has a stable link.

  1. F-1390

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

  2. F-1392

    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.

  3. F-1391

    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.

  4. F-1393

    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.

  5. F-1394

    CMS lacked staff and resources to perform this function.

  6. F-1395

    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)

  1. R-1245

    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).

    Related finding F-1395
  2. R-1246

    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.

    Related finding F-1393