Current Report Articles
Conditions of Participation and Interpretive Guidance Communication

Survey3 (Sept. 12, 2025) – With the rapid rate of change in Conditions of Participation and the resulting Interpretive Guidance for surveyors, it is challenging to keep pace for you and those responsible for survey readiness and compliance. To keep up with communications from the Centers for Medicare & Medicaid Services, go to Policy & Memos to States and CMS Locations on the CMS website. This is where CMS releases and archives Quality, Safety and Oversight memoranda, guidance, clarifications and instructions to State Survey Agencies and CMS locations. The site provides information and guidance on the Conditions of Participation for all hospital types, as well as nursing facilities and CLIA-regulated clinicians.

For example, on Sept. 5, they released QSO-25-24-Hospitals to provide revisions to the State Operations Manual – Appendix A for PPS hospitals. CMS states, "This will accomplish two objectives: The first is to issue new interpretive guidance and survey processes for Conditions of Participation (CoPs) that were finalized and established in 2019 and 2020. The publication of this guidance was delayed due to COVID-19 public health priorities. The second portion of this update is to incorporate previously issued guidance from QSO memos S&C-16-29, 19-13 (revised), QSO-20-04, 22-20, 23-09, and QSO-23-19 into the SOM."

This is great information to share with your leadership and survey readiness teams.
--Larry Van Der Wege