September 8, 2026 – As the Centers for Medicare & Medicaid Services (CMS) begins nationwide implementation of its new Risk-Based Survey (RBS) process today, LTCCC is releasing a new guide to help Long-Term Care Ombudsmen understand the process, respond to questions about facilities considered “higher performing” or “low risk,” and provide surveyors with information about resident-care concerns.
Under the RBS, survey teams will conduct significantly fewer survey activities, review a smaller sample of residents, use fewer surveyors, and spend roughly half as much time onsite as they would during a traditional standard survey. Infection control is the only mandatory facility task; other important areas – including staffing, dining, resident council, medication administration, and the facility environment – are reviewed only when particular concerns are identified, such as a by an ombudsman.
Beginning September 30, CMS plans to place a golden trophy icon on Care Compare profiles for facilities that qualify for these abbreviated surveys. However, the designation should not be viewed as proof that a facility provides high-quality or safe care. A facility may qualify with only a three-star staffing rating, and CMS’s criteria may not capture current problems, unreported incidents, or deficiencies that surveyors failed to identify.
Ombudsman input is critical! The RBS Procedure Guide directs surveyors to contact the Long-Term Care Ombudsman Program before entering a facility and obtain information about identified concerns. Because the RBS involves fewer survey activities and a smaller resident sample, timely and specific information from ombudsman may be essential to ensuring that problems are investigated.
LTCCC’s new guide provides ombudsmen with practical information on:
- What the RBS changes – and what remains the same;
- Which nursing homes can qualify for abbreviated surveys;
- How to respond to questions about the “high-performing” designation;
- Information to prepare when contacted by surveyors;
- Questions surveyors may ask and suggested approaches for responding; and
- Important cautions concerning resident consent and confidentiality.
A golden trophy is not a guarantee of good care. Ombudsman should continue to focus on residents’ experiences, present facility conditions, and whether each resident is receiving the care and services required by law.