CMS Updates Guidance on Survey and Certification Activities During Federal Shutdown

CMS Updates Guidance on Survey and Certification Activities Amid Federal Shutdown

QSO-26-01-ALL (Revised) • Issued October 21, 2025

The Centers for Medicare & Medicaid Services (CMS) issued revised guidance for how State Survey Agencies (SAs) and accrediting organizations should operate during the federal shutdown. The memo (revisions shown in red in the CMS document) clarifies which activities are considered “excepted” (essential) and may continue, and which are paused until funding is restored.

CHAP has confirmed its survey operations remain unaffected; accreditation surveys for home health and hospice providers will continue as usual.

Highlights for Home Health & Hospice Providers

• Routine federal surveys paused: CMS has suspended Medicare-funded recertification and initial surveys for most provider types, including HHAs, until appropriations are restored.
• Hospice surveys continue: Activities funded under the Consolidated Appropriations Act of 2021 are not impacted.
• Complaint investigations (IJ/harm): Allegations of immediate jeopardy or actual harm will continue to be assessed and investigated; SAs do not need prior CMS approval for deemed providers.
• Limited revisits: Allowed only when needed to prevent Medicare termination or denial of payment for new admissions.
• State-funded & Medicaid-only surveys: May proceed, as they rely on state or mandatory Medicaid funding.
• Activities that must pause: Routine recertifications, informal dispute resolutions, initial certifications, and most enforcement processing are suspended during the shutdown.
• OASIS & MDS: Continue only essential reporting to maintain data integrity.

Key takeaway: Routine federal survey activity is on hold for most providers, but complaint investigations involving harm and hospice surveys funded through the CAA will continue. CHAP-accredited providers should expect surveys to proceed normally.

CMS Confirms Medicare Claims Processing Will Continue During Shutdown

In a separate notice, CMS confirmed that Medicare claims will continue to be processed and paid on schedule during the shutdown, with limited exceptions for services tied to expired statutory provisions. The National Alliance has verified with the Medicare Administrative Contractor (MAC) that home health and hospice claims are not subject to payment holds, and no delays are expected beyond normal timelines.

HCA will continue monitoring developments and share any updates affecting provider billing or reimbursement.

Note: If your agency has survey activity scheduled, confirm status with your accreditor or SA.