CMS issues memo with contingency plans for state survey & certification activities in the event of federal government shutdown

CMS issues memo with contingency plans for state survey & certification activities in the event of federal government shutdown 
CMS - Center for Clinical Standards and Quality; by CMS Directors, Quality, Safety & Oversight Group (QSOG) and Survey & Operations Group (SOG); 10/1/25 
On October 1, 2025, CMS issued QSO-26-01-ALL identifying State Survey and Certification functions that (a) are not affected by a Federal shutdown, (b) excepted functions that are to be continued in the event of a shutdown (also referred to as “essential functions”), and (c) other activities that are directly affected and therefore should not be operational during a Federal shutdown. CMS also clarified that Hospice Surveys funded through the Consolidated Appropriations Act (CAA) of 2021are considered mandatory and are not impacted by the Federal Government shutdown. Work funded under these sources should continue.

Essential Medicare functions during the shutdown:

1. Complaint investigations alleging harm
2. Certain Federal enforcement actions
3. Revisit surveys approved by exception and necessary to prevent termination
4. Immediate threats to life or safety (emergencies and natural disasters)
5. Orderly shutdown of other tasks.

Activities not supported or conducted during the Federal government shutdown:

1. Standard surveys
2. Certain revisit surveys
3. Initial surveys
4. Initial certification via deemed status
5. Certain complaint investigations
6. MDS or OASIS – no activities
7. Informal Dispute Resolution – not conducted
8. New CMP-funded improvement project – no new projects to be funded