Illustrated graphic labeled CMS Changes 2025.

CMS 2025 Survey Changes: A Guide for Long-Term Care Leaders

December 05, 2024•5 min read

Historical article: this post discusses guidance, research, or events from its original publication period. Time-specific requirements should be checked against the current primary source before operational use.

Major revisions to the CMS long-term care survey process (QSO-25-07-NH) will take effect on February 24, 2025. These updates will redefine how compliance is evaluated and require immediate action from leadership teams to ensure readiness.


At SMK Medical, we understand the stakes and the challenges these changes pose. Let’s break down the key updates and how your organization can prepare.


Top Survey Changes Requiring Immediate Action


1. Admission & Discharge Process Overhaul


  • Regulatory Consolidation: Tags F622-F626 and F660-F661 have been consolidated into two citations:F627: Inappropriate Transfers and DischargesF628: Transfer and Discharge Process
  • Key Update: Admission agreements can no longer include third-party payment guarantees.
  • Terminology like “facility-initiated” and “resident-initiated” has been eliminated, streamlining discharge policies.

2. Psychotropic Medication Management Overhaul


  • Revised Guidance: F758 requirements are now integrated into F605.
  • New Standards:Resident notification and participation before initiating or increasing psychotropic medications.Documentation of a resident's right to accept or decline medication.
  • Medications for staff convenience or sedation face heightened scrutiny.

3. Medical Director Accountability


  • Expanded responsibility for ensuring adherence to care policies.
  • Direct involvement in medication oversight and integration into the QAPI process.

4. MDS Assessment Accuracy


  • Enhanced documentation for F641 (Accuracy of Assessment).
  • Requirements for antipsychotic medication justification and significant change assessments.

5. QAPI Program Enhancement


  • New Focus Areas: Health equity integration.Data analysis on race, socioeconomic status, and medical errors.
  • Mandatory review of adverse events and population-specific outcomes.

6. Clinical Care Updates


  • Key Areas of Change:Updated CPR certification requirements.Revised CDC-aligned pain management guidelines. New opioid prescribing standards.Enhanced infection control for MDROs and updated COVID-19 immunization guidance.

Action Plan for Leadership Teams


1. Policy Review (Deadline: January 2025)


  • Revise admission agreements, psychotropic medication protocols, and QAPI documentation.
  • Align MDS procedures with updated requirements.

2. Staff Training


  • Update competency programs and documentation protocols.
  • Implement new assessment tools.

3. Systems Updates


  • Enhance MDS documentation systems and tracking mechanisms.
  • Upgrade quality monitoring protocols.

How SMK Medical Can Help Your Facility Thrive


The regulatory landscape is changing, but SMK Medical is here to guide your team every step of the way.


What We Offer:


  • Mock Surveys: Tailored to address the 2025 survey changes.
  • MDS Support: Documentation reviews and training to improve accuracy and compliance.
  • Policy Development: We help you rewrite outdated protocols.
  • QAPI Enhancement: Ensure your program meets new equity and data requirements.

Strategic Solutions:


  • Gap analyses to identify vulnerabilities.
  • Development of implementation timelines.
  • Risk assessment and mitigation planning.

Breaking Down CMS's 2025 Survey Changes: Executive Guidance for LTC Leaders


Critical Alert: Major revisions to the CMS long-term care survey process (QSO-25-07-NH) will take effect on February 24, 2025. These updates will redefine how compliance is evaluated and require immediate action from leadership teams to ensure readiness.


At SMK Medical, we understand the stakes and the challenges these changes pose. Let’s break down the key updates and how your organization can prepare.


Top Survey Changes Requiring Immediate Action


1. Admission & Discharge Process Overhaul

  • Regulatory Consolidation: Tags F622-F626 and F660-F661 have been consolidated into two citations:F627: Inappropriate Transfers and DischargesF628: Transfer and Discharge Process
  • Key Update: Admission agreements can no longer include third-party payment guarantees.
  • Terminology like “facility-initiated” and “resident-initiated” has been eliminated, streamlining discharge policies.

2. Psychotropic Medication Management Overhaul

  • Revised Guidance: F758 requirements are now integrated into F605.
  • New Standards:Resident notification and participation before initiating or increasing psychotropic medications.Documentation of a resident's right to accept or decline medication.
  • Medications for staff convenience or sedation face heightened scrutiny.

3. Medical Director Accountability

  • Expanded responsibility for ensuring adherence to care policies.
  • Direct involvement in medication oversight and integration into the QAPI process.

4. MDS Assessment Accuracy

  • Enhanced documentation for F641 (Accuracy of Assessment).
  • Requirements for antipsychotic medication justification and significant change assessments.

5. QAPI Program Enhancement

  • New Focus Areas:Health equity integration.Data analysis on race, socioeconomic status, and medical errors.
  • Mandatory review of adverse events and population-specific outcomes.

6. Clinical Care Updates

  • Key Areas of Change:Updated CPR certification requirements.Revised CDC-aligned pain management guidelines.New opioid prescribing standards.Enhanced infection control for MDROs and updated COVID-19 immunization guidance.

Action Plan for Leadership Teams


1. Policy Review (Deadline: January 2025)

  • Revise admission agreements, psychotropic medication protocols, and QAPI documentation.
  • Align MDS procedures with updated requirements.

2. Staff Training

  • Update competency programs and documentation protocols.
  • Implement new assessment tools.

3. Systems Updates

  • Enhance MDS documentation systems and tracking mechanisms.
  • Upgrade quality monitoring protocols.

How SMK Medical Can Help Your Facility Thrive


The regulatory landscape is changing, but SMK Medical is here to guide your team every step of the way.


What We Offer:

  • Mock Surveys: Tailored to address the 2025 survey changes.
  • MDS Support: Documentation reviews and training to improve accuracy and compliance.
  • Policy Development: We help you rewrite outdated protocols.
  • QAPI Enhancement: Ensure your program meets new equity and data requirements.

Strategic Solutions:

  • Gap analyses to identify vulnerabilities.
  • Development of implementation timelines.
  • Risk assessment and mitigation planning.

Act Now to Protect Your Compliance


Don’t risk costly deficiencies in 2025. Prepare today by partnering with SMK Medical to secure your facility’s compliance and operational success.


📞 Call us: 313-314-8267 🌐 Visit us: SMKMed.com


With decades of experience in post-acute care, SMK Medical is your trusted partner in navigating these critical updates. Let’s prepare together for a stronger future.

Dr Demetrius Kirk

Dr Demetrius Kirk

Dr. Demetrius “DJ” Kirk is the Founder and CEO of SMK Medical, a healthcare consulting firm specializing in long-term care regulatory compliance, survey readiness, quality improvement, and operational excellence. A healthcare executive, Registered Nurse, and Licensed Nursing Home Administrator, Dr. Kirk brings extensive experience in post-acute care leadership, including executive, regional, and clinical management roles. His expertise includes CMS regulations, nursing home surveys, risk management, MDS and PDPM optimization, QAPI, and leadership development. Through his writing, Dr. Kirk translates complex regulatory requirements into practical strategies that help healthcare leaders strengthen compliance, improve quality outcomes, and build high-performing teams.

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