Informal dispute resolution · Independent informal dispute resolution
Dispute an unfair citation before the deadline passes
When a survey cites your facility for something the record does not support, you have a short window to challenge it. Our team builds the evidence, writes the request, and prepares you for the review, while your Plan of Correction stays on schedule.
Call the day you receive your CMS-2567. The 10-day clock starts when the statement of deficiencies arrives, and a weak request is hard to fix later.
Know your options
Two ways to challenge a deficiency
Both processes let you dispute citations that are not supported by the facts. Which one applies depends on whether a civil money penalty was imposed.
Informal dispute resolution (IDR)
Run by your state survey agency
- Available for any cited deficiency you believe is not supported
- Requested within the same 10 calendar days you have to submit your Plan of Correction
- Can be a desk review, phone conference, or meeting, depending on your state
- Deficiencies removed or changed are reflected on the CMS-2567
Independent informal dispute resolution (IIDR)
Reviewed by an independent entity
- Available when CMS imposes a civil money penalty tied to the deficiency
- Requested within 10 calendar days of the civil money penalty notice
- Reviewed by an organization independent of the survey team
- Completed within 60 days of your request
What these processes cannot do
Informal dispute resolution does not pause your Plan of Correction deadline or delay enforcement. Scope and severity generally cannot be disputed unless the citation rises to substandard quality of care or immediate jeopardy. That is why we work the Plan of Correction and the dispute at the same time.
How we help
From the CMS-2567 to the review, step by step
Our team includes a licensed nursing home administrator and registered nurses who have run buildings and lived through survey. We read a citation the way a surveyor wrote it and the way a reviewer will judge it.
- 01
Same-day citation review
We read every tag on the statement of deficiencies and tell you which ones are worth disputing and which are better corrected.
- 02
Evidence and timeline
We pull the clinical record, policies, staffing, and interviews, and build a minute-by-minute timeline that shows what actually happened.
- 03
Written request
We draft the dispute tied to the federal regulation and surveyor guidance, citing the exact pages of evidence that contradict the finding.
- 04
Plan of Correction in parallel
Your Plan of Correction is still due on time. We write it so it stays accurate whether or not the dispute succeeds.
- 05
Review preparation
We prepare your administrator and director of nursing for the conference or desk review, including the questions reviewers ask.
- 06
Next steps after the decision
If citations stand, we coordinate with your legal counsel on formal appeal options and keep your survey readiness moving.
Why it matters
One citation can follow you for years
Deficiencies drive your Five-Star health inspection rating, enforcement history, insurance, and referral relationships. A citation that should not be there is worth challenging.
- Protect your Five-Star health inspection rating
- Reduce or remove civil money penalty exposure
- Keep an accurate enforcement history for future surveys
- Show staff and families the facts were reviewed
Good to know
SMK Medical is a clinical and regulatory consulting firm, not a law firm. For formal appeals and litigation, we work alongside your attorney and supply the clinical and operational analysis.
Related help
Survey response and Plans of Correction · Mock surveys · Special Focus Facility support
Questions
Dispute resolution FAQs
How fast do we need to call you?
As soon as the statement of deficiencies arrives. The request is due within the same 10 calendar days as your Plan of Correction, and the evidence takes time to pull.
Can we dispute a citation and still submit a Plan of Correction?
Yes, and you must. Requesting informal dispute resolution does not extend the Plan of Correction deadline. We prepare both at the same time.
When can we use independent informal dispute resolution?
When CMS imposes a civil money penalty connected to the cited deficiency. The request is due within 10 calendar days of the penalty notice.
Can we dispute the scope and severity?
Generally only when the citation is at the level of substandard quality of care or immediate jeopardy. Most disputes focus on whether the facts support the deficiency at all.
Do you work with facilities outside Michigan?
Yes. We support facilities nationwide and follow each state survey agency’s procedure.
The clock is running
Received a CMS-2567 you do not agree with?
Call now and we will review your citations the same day.
Informal dispute resolution
Disputing a citation? You have 10 days.
- Same-day review of your statement of deficiencies
- Evidence, timeline, and written request built for you
- Plan of Correction kept on schedule