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The Risk-Based Survey Is Live September 8: Here's What Actually Changes

Written by Showd.me | Sep 1, 2026, 4:20:15 PM

If you feel like you’ve been hearing about the Risk-Based Survey for a while now, you're not imagining things… CMS has been piloting this approach since 2024, and it's finally here! On July 16, CMS confirmed that the new Risk-Based Survey (RBS) goes live nationwide on September 8, 2026.

This is good news for providers who've spent years investing in quality and doing it right. But it’s also a meaningful shift in how CMS approaches oversight,so it's worth understanding well. Here's what's confirmed, what's still evolving, and what's worth paying attention to this month.

 

What is RBS?

RBS is a modified version of the standard Long-Term Care Survey Process. Surveyors still review every required area of the Requirements for Participation, but what changes is the shape of the visit: a smaller resident sample, fewer survey activities, and roughly half the on-site time, run by a smaller survey team. CMS has said the pilot data showed RBS identifies noncompliance and resident risk at rates comparable to a standard survey. So the best way to describe this to your team is: same bar with a faster process, not a lower bar.

Every facility, RBS-eligible or not, still gets a standard recertification survey at least once every 15 months. RBS doesn't replace that cycle; it changes what happens within it for facilities that qualify.

Who Qualifies?

CMS rechecks which facilities qualify for RBS every quarter, and the list is pretty demanding. To qualify, a facility currently needs:

  • A five-star overall rating on Care Compare
  • A staffing star rating of at least 3 stars
  • A health inspection score at or below the state's 50th percentile
  • No actual harm, Immediate Jeopardy, or substandard-quality-of-care citations in the last survey cycle
  • A standard survey completed within the last 18 months
  • No active staffing waiver
  • No failed PBJ or MDS data audit
  • No ownership change since the last standard survey
  • No status as a Special Focus Facility candidate

Only about 12% of nursing homes nationally currently meet all of those criteria, equalling roughly 1,560 out of nearly 14,700 facilities based on CMS's own preliminary numbers. That number is expected to shift as more recent data comes in, but it tells us that this is a real quality threshold that most facilities haven’t quite met yet. This isn’t a reason for discouragement; instead, think of it as a roadmap. The criteria are specific and known, which means the path to closing that gap is too.

And for the facilities that are already there: eligibility isn't a badge you earn once and keep. It's reassessed every quarter, and it's not event locked in even within a quarter. If a harm-level citation, an abuse finding, or a handful of other triggering events happens before the survey actually starts, state agencies are required to convert it back to a standard survey. So qualifying once isn't the finish line. It's a signal that whatever protective measures got you there need to be hardwired into daily practice. RBS eligibility is something you maintain over time, not something you bank.

What Families Will Start Seeing

Qualifying facilities will also get a "high performer" icon on Nursing Home Care Compare.

Families researching placement have long relied on Five-Star ratings, but that number updates on its own schedule and blends several inputs into one score. The high-performer icon is a bit different, in that it is tied directly to the RBS qualifying criteria. This means it's a fresher, more pointed signal for families: this facility currently meets a specific, quarterly-verified bar for citation history, staffing, and audit accuracy, on top of whatever its Five-Star rating already shows.

In practice, that means families comparing two five-star facilities may now see one with the icon and one without, a distinction likely to catch attention, especially for families who already dig into Care Compare data before making a decision. It's a second, public-facing marker sitting right alongside your Five-Star rating, and it's one more thing prospective residents and their families will start noticing this fall.

What This Means For You & Your Team

Whether or not your facility is RBS-eligible today, the practical answer doesn't change much. The facilities that will do well under either survey type are the ones where survey readiness is a daily habit: documentation that's accurate in real time, staff who know what's expected of them without a pre-survey scramble, and a training culture that doesn't spike the week before you think surveyors might show up. RBS rewards that. So does a standard survey.

How Showd.me Can Help

Survey readiness is the byproduct of consistent, well-documented training and a workforce that understands compliance as part of the job, not a separate event. That's the gap Showd.me is built to close: role-specific compliance training, real-time completion tracking, competency validation, and documentation you can actually stand behind when a surveyor asks for it.

If you're not sure where your facility stands against the RBS criteria, or you want a clearer picture of your training and documentation readiness heading into survey season, let's talk. We'd rather help you get ahead of this than help you recover from it.