CMS 2025 Revision: Comprehensive Update to Long Term Care Surveyor Guidelines

On November 18, 2024, CMS announced its intention to revise LTC Surveyor Guidance. The changes will focus on different areas ranging from administrative agreements and medication management to infection control and health equity considerations.

The guidance will be available to surveyors on February 24, 2025.

Here is a summary of notable changes in the new Surveyor Guidance:

F641

One important change relates to citations in F641 for the accuracy of assessment, whereby surveyors are instructed to review minimum data set (MDS) coding accuracy, but not investigate possible falsification of the MDS. The guidance requires surveyors to refer to OIG any three or more inaccurate MDS coding for residents as possible falsification.

Admission, Transfer, and Discharge

There are a few significant changes under this heading. To prevent financial coercion, under the new guidance facilities may no longer include language in their admission agreements that requests or requires a third-party guarantee of payment.

CMS is also removing several outdated tags, including F622 through F626 and F660 through F661, which previously dealt with facility-initiated and resident-initiated transfers and discharges. Two new citations will take the place of these removed tags. The revisions aim to make it easier for surveyors to identify instances of noncompliance, especially those related to transfers or discharges which violate patients’ rights.

Chemical Restraints/Unnecessary Psychotropic Medication

Regulation concerning the unnecessary use of psychotropic medications is located under F758 tag. The new guidance now incorporates the regulations under F605 to simplify the survey process and increase consistency in enforcement. Tag F757, addressing unnecessary medications, has also been changed to only include guidance for non-psychotropic medications.

The change highlights the need for facilities to prevent the unnecessary administration of psychotropic drugs to patients, especially when used for the convenience of staff.

The guidance further requires that patients should be notified of their rights to participate in their treatments and their rights to refuse or accept medication.

Infection Control

The new guidance incorporates enhanced precautions for preventing the spread of multi-resistant organisms (MDROs).

COVID-19 Update

CMS integrated updated COVID-19 immunization guidance into the survey process. Facilities will be required to offer all residents and staff COVID-19 vaccinations as part of an ongoing infection control effort, provide education about the benefits and risks of COVID-19 shots, and document any refusal or contraindication.

QAPI Health Equity Measures

The guidance will require facilities to collect data on factors that affect health equity, such as race, socioeconomic status, and language, and that this data is used to inform the facility's priorities and improvement efforts.

Facilities Medical Director Responsibilities

The guidance clarifies the responsibility of the facility's medical director, under tag F841. The facility medical director is now responsible for overseeing the implementation of and compliance with the resident care policies. Under the updated surveyor guidance, Medical Directors are no longer viewed as passive or administrative figures — CMS now emphasizes active oversight, clinical leadership, and direct involvement in quality and compliance activities. The revised guidance clarifies that Medical Directors are expected to:

• Participate in Quality Assessment and Assurance (QAA/QAPI) activities
• Support implementation of resident care policies
• Intervene when physician practices are inconsistent with professional standards
• Oversee coordination of medical care across the facility
• Actively contribute to the facility assessment process

CMS also placed increased focus on documentation, psychotropic medication oversight, and diagnostic accuracy — particularly related to schizophrenia diagnoses and unnecessary medications. Surveyors are now instructed to evaluate whether Medical Directors are actively addressing concerns identified through audits, quality reviews, and medication management processes.

For long-term care organizations, these revisions reinforce the importance of having centralized, accurate, and survey-ready credentialing and compliance systems. Facilities relying on spreadsheets, paper files, or fragmented workflows may struggle to demonstrate the level of oversight, coordination, and documentation now expected under F841.

The revised CMS guidance highlights the growing importance of proactive oversight, accurate documentation, and workforce accountability in long-term care. Perla helps organizations meet these evolving CMS expectations by streamlining credentialing, compliance tracking, OIG monitoring, training documentation, and staff record management through a centralized and automated platform. This allows facilities to reduce administrative burden, improve survey readiness, and maintain greater visibility into workforce compliance across the organization. Call us if you need support in credentialing and compliance for your facility at 202-800-5858

‍