Few events create more anxiety in a skilled nursing facility than the arrival of CMS surveyors. The unannounced nature of standard surveys, combined with the stakes involved -- potential citations, fines, and public reporting on Care Compare -- makes survey preparation one of the most critical ongoing responsibilities for any SNF administrator.
But here is the truth that seasoned operators understand: survey readiness is not a last-minute scramble. It is a culture. Facilities that perform well on surveys do so because they have embedded compliance into their daily operations, not because they crammed the week before a surveyor showed up.
This guide provides a comprehensive, actionable checklist organized by category so your facility can maintain a state of perpetual readiness throughout 2026.
Understanding CMS Surveys in 2026
Before diving into the checklist, it helps to understand what you are preparing for. The Centers for Medicare & Medicaid Services (CMS) conducts several types of surveys for skilled nursing facilities:
Standard (Annual) Surveys
These are unannounced inspections that occur approximately every 9 to 15 months. Surveyors evaluate compliance with federal participation requirements across all aspects of care and operations. The survey team typically includes registered nurses, a dietitian, a life safety code inspector, and sometimes a pharmacist or social worker.
Complaint Surveys
Triggered by complaints from residents, families, staff, or other sources. These are also unannounced and can happen at any time, including evenings and weekends. Complaint surveys are narrowly focused on the allegations but can expand if surveyors identify other concerns.
Focused Surveys
Targeted investigations that examine specific areas of care or compliance. These may follow up on previous deficiencies or address specific regulatory concerns identified by CMS.
Life Safety Code (LSC) Surveys
These evaluate your physical plant and fire safety systems against NFPA 101 Life Safety Code requirements. They may be conducted alongside or separately from the standard health survey.
In 2026, surveyors continue to use the Quality Indicator Survey (QIS) or the traditional survey process depending on your state. Regardless of the methodology, the fundamentals of preparation remain the same.
Documentation Readiness Checklist
Documentation is where most facilities either shine or stumble. Surveyors review records extensively, and incomplete or inconsistent documentation is one of the fastest paths to a citation.
Resident Records
- Care plans are current and individualized. Every resident should have a comprehensive care plan that reflects their current condition, preferences, and goals. Care plans must be updated after every significant change in condition and at minimum quarterly.
- MDS assessments are timely and accurate. Verify that all Minimum Data Set assessments are completed within required timeframes (admission, quarterly, annual, significant change, and discharge). Cross-reference MDS coding with clinical documentation to ensure consistency.
- Physician orders are signed and current. Check that all orders -- including telephone and verbal orders -- are signed within your state's required timeframe. Ensure there are no expired or contradictory orders.
- Advance directives are documented and honored. Confirm that each resident's file contains their advance directive or a notation that they were offered the opportunity to create one. Verify that staff know where to find this information.
- Medication administration records (MARs) match physician orders. Conduct regular audits to confirm that medications documented on MARs correspond to active physician orders. Look for gaps, inconsistencies, or unsigned entries.
Facility-Level Documentation
- Policies and procedures are up to date. Review all P&P documents to ensure they reflect current CMS regulations, state requirements, and actual facility practices. Pay special attention to infection control, abuse prevention, and emergency preparedness policies.
- QAPI program documentation is current and complete. Your Quality Assurance and Performance Improvement program should have a written plan, documented committee meetings, identified performance improvement projects (PIPs), and measurable outcomes. Surveyors will ask to see this.
- Grievance and complaint logs are maintained. Document all grievances, the investigation conducted, and the resolution. Response timeframes matter -- CMS expects prompt attention to resident concerns.
- Training records are complete. Maintain sign-in sheets and completion records for all required training: abuse prevention, infection control, HIPAA, fire safety, dementia care, and any state-specific requirements.
Staffing Readiness Checklist
CMS places enormous emphasis on staffing. The federal staffing mandate finalized in 2024 has added new layers of accountability, and surveyors will scrutinize your staffing levels, competency, and consistency.
Staffing Levels and Compliance
- Verify compliance with federal minimum staffing requirements. As of 2026, facilities must meet the CMS staffing mandates, which include minimum hours per resident day (HPRD) for RNs, nurse aides, and total nursing staff. Know your numbers and track them daily.
- PBJ submissions are accurate and timely. Payroll-Based Journal data directly feeds your staffing metrics on Care Compare. Ensure your submissions are reconciled and error-free each quarter.
- Staffing schedules match actual hours worked. Surveyors may compare your posted schedules to timekeeping records and PBJ submissions. Discrepancies raise red flags.
- Agency staff usage is documented and supervised. If you use agency or contract staff, ensure they receive facility orientation, have access to relevant policies, and are supervised by permanent staff.
Staff Competency
- Nurse aide certifications are current. Verify that every CNA has a valid, non-expired certification and is in good standing on the state nurse aide registry.
- Competency evaluations are on file. Annual competency evaluations for nursing staff should be documented, including skills checklists and any remediation plans.
- Licensed staff credentials are verified. Confirm that all RNs and LPNs have active licenses with no disciplinary actions. Document your verification process.
- Staff can articulate care plans. This is a practical test -- surveyors will ask frontline staff about specific residents. Staff should be able to describe a resident's care needs, preferences, and current plan of care.
Clinical Readiness Checklist
Clinical care is the heart of the survey. Surveyors will observe care delivery, review clinical outcomes, and interview residents and staff about the quality of care provided.
Medication Management
- Medication storage is secure and organized. Controlled substances are double-locked, refrigerated medications are within temperature range (with logs), and expired medications are removed promptly.
- Medication passes are observed for proper technique. Staff should be administering medications at the correct time, verifying resident identity, documenting refusals, and following the five rights of medication administration.
- Psychotropic medication use is justified and monitored. This is a perennial hot-button area. Every resident on an antipsychotic, anxiolytic, or hypnotic must have a clinical indication documented, behavioral interventions attempted first, and gradual dose reduction (GDR) attempts unless clinically contraindicated.
- PRN medication usage is monitored. Track the frequency of PRN medications and ensure follow-up assessments are documented within the required timeframe after administration.
Infection Prevention and Control
- Infection preventionist (IP) is designated and trained. CMS requires a designated IP with specialized training. Verify credentials and ensure this person has dedicated time for infection control duties.
- Antibiotic stewardship program is active. Document your program, track antibiotic use, and demonstrate that prescribing follows established protocols.
- Hand hygiene compliance is monitored. Conduct and document regular hand hygiene audits. Address non-compliance through education and accountability.
- Isolation protocols are followed correctly. Ensure staff understand and implement transmission-based precautions appropriately, with correct signage and available PPE.
Resident Rights and Quality of Life
- Residents are free from physical and chemical restraints unless clinically necessary. If restraints are used, ensure proper physician orders, assessments, monitoring, and release schedules are documented.
- Residents have access to their personal belongings and preferences. Room temperatures, food preferences, activity choices, and daily routines should reflect resident preferences as documented in care plans.
- Abuse prevention program is active and effective. Staff know how to report suspected abuse, the facility investigates allegations promptly, and all incidents are reported to the state as required.
Environmental and Life Safety Checklist
The physical environment of your facility matters more than many administrators realize. Environmental deficiencies are common and often easily preventable.
General Environment
- Facility is clean, odor-free, and well-maintained. Walk your building with fresh eyes. Look for stained ceiling tiles, peeling paint, damaged flooring, and persistent odors. These are easy citations.
- Call lights are functional and answered promptly. Test call lights regularly and track response times. Surveyors will time response during their visit.
- Water temperatures are within safe range. Hot water at fixtures accessible to residents must not exceed 120 degrees Fahrenheit. Test and document regularly.
- Resident rooms are personalized and homelike. The environment should feel residential, not institutional. Residents should have personal items, photos, and furnishings that reflect their preferences.
Life Safety Code
- Fire drills are conducted and documented. Facilities must conduct fire drills at least quarterly per shift (some states require monthly). Document participation, response times, and any corrective actions.
- Fire doors, smoke detectors, and sprinklers are inspected and functional. Maintain inspection logs for all fire safety systems. Address deficiencies immediately.
- Exit corridors are clear of obstructions. Walk all corridors and exits daily. Stored equipment, linen carts, and other items in corridors are common citations.
- Emergency generator is tested and maintained. Weekly testing under load, with documented maintenance records, is required. Fuel supply must meet minimum requirements.
- Kitchen hood suppression systems are inspected. Semi-annual inspections by a certified vendor, with documentation on file.
Common Deficiencies to Watch For
Understanding the most frequently cited deficiencies can help you prioritize your preparation efforts. Based on recent survey data, these F-tags appear consistently among the most cited:
- F880 -- Infection Prevention and Control: Proper hand hygiene, PPE use, and adherence to transmission-based precautions remain the most cited area.
- F689 -- Free from Accident Hazards: Falls prevention programs, hazard assessments, and supervision adequacy are heavily scrutinized.
- F684 -- Quality of Care: This broad tag covers the facility's obligation to provide care that meets professional standards of practice.
- F812 -- Food Procurement, Storage, Preparation, and Service: Kitchen sanitation, food temperatures, and dietary accommodations are common problem areas.
- F761 -- Label/Store Drugs and Biologicals: Medication storage, labeling, and expiration monitoring continue to generate citations.
Preparing Your Staff for Surveyor Interactions
Your staff's interaction with surveyors can make or break a survey. Preparation should include both knowledge and composure.
Interview Preparation Tips
- Train staff to be honest and direct. Coaching staff to give specific answers is appropriate. Coaching them to hide problems is not -- and surveyors are trained to detect it.
- Ensure staff know their residents. CNAs should be able to describe their assigned residents' care needs, preferences, and recent changes without consulting a chart.
- Practice common surveyor questions. "What would you do if a resident fell?" "How do you report suspected abuse?" "What is this resident's diet order?" Staff who can answer these confidently project competence.
- Designate a survey coordinator. One person should be responsible for managing the survey process: escorting surveyors, gathering requested documents, and coordinating staff availability for interviews.
- Remind staff about professionalism. Appropriate attire, name badges visible, respectful language, and a calm demeanor all contribute to a positive impression.
Building a Culture of Continuous Readiness
The facilities that perform best on CMS surveys are those that treat every day as survey day. This means:
- Conducting regular mock surveys. At minimum, quarterly internal audits that mirror the actual survey process. Use the same tools and protocols that state surveyors use.
- Implementing a daily environmental rounding program. Department heads should walk their areas daily, identifying and correcting issues before they become citations.
- Holding weekly QAPI meetings. Brief, focused meetings that review quality indicators, incident trends, and active performance improvement projects.
- Creating accountability at every level. From the administrator to the newest CNA, everyone should understand their role in maintaining compliance and quality.
Take the Next Step Toward Survey Readiness
Preparing for a CMS survey does not have to be overwhelming, but it does require intentionality, organization, and expertise. If your facility needs help building a state of continuous survey readiness -- whether that means conducting a mock survey, training your staff, or developing a comprehensive compliance program -- we can help.
Learn more about our SNF Survey Readiness services and schedule a consultation with our team. We work alongside your leadership to build the systems, training, and culture that turn survey preparation from a source of anxiety into a source of confidence.