All Surveys Must Be Unannounced

7207.2 - All Surveys Must Be Unannounced (Rev. 244; Issued: 06-26-26; Effective: 06-26-26; Implementation: 06-26-26) The State has the responsibility for keeping surveys unannounced and their timing unpredictable. This gives the State agency doing the surveying greater ability to obtain valid information because it increases the probability that the surveys will observe conditions and care practices that are typically present. While the Act and implementing regulations referenced in §7207.1 require that standard surveys be unannounced, it is CMS’ intention and expectation to not announce any type of nursing home survey such as abbreviated, onsite revisit, or complaint surveys. Therefore, if CMS conducts standard surveys or validation surveys, the CMS Location must follow the same procedures as required of the States to not announce surveys. The only exceptions to this policy would be if, for instance, some additional documentation was required and the most efficient way to obtain it would be through making an appointment and revisiting the facility or asking that it be provided via electronic means. The State should notify the State ombudsman’s office according to the protocol developed between the State and the State ombudsman’s office. This protocol must ensure strict confidentiality concerning the survey dates. (See the LTCSP Procedure Guide.) Survey teams are expected to remain in the facility after entrance for a minimum of five consecutive hours. This applies to all standard health surveys and helps to ensure that the surveys remain unannounced. For example, a survey team should not enter a facility, conduct a brief entrance conference, then leave the facility only to return the next day. Additionally, a survey should not enter a facility on a Friday and not return until the following Monday. If all required first day activities (per the LTCSP procedure guide and entrance conference form) have been completed in under five hours, or there is an emergency, the survey team may leave sooner, but this should be a rare occurrence. At a minimum, the first two days of a survey must be conducted on consecutive calendar days from the day of entrance. The only exception would be an emergency situation, which should be rare, or a competing IJ at another location requiring the survey team’s immediate attention. To increase the opportunity for unpredictability in standard surveys, the State survey agencies and Federal surveyors should incorporate the following procedures when planning facility surveying: