A recent memo from the Centers for Medicare & Medicaid Services (CMS) puts the Special Focus Facility (SFF) reporting process back on track after the agency briefly paused data collection this summer to account for the transition to a cloud-based Internet Quality Improvement and Evaluation System (iQIES) for nursing home survey and certification data.

CMS said instead of the original projection for the technical pause to last until October, it is now complete as data collection for Nursing Home Care Compare and SFF status resumed as of this week (Sept. 24).

All other information on Nursing Home Care Compare, including health inspection star ratings, will continue to be based on July 30, 2025, data. Regular data refreshes are anticipated in October, CMS said.

“This temporary pause allows CMS to validate data integrity and verify that publicly reported information meets CMS quality standards before resuming updates. Nursing homes are still required to maintain transparency by displaying their most recent survey findings (CMS-2567 Statement of Deficiencies) in a publicly accessible area within the facility,” the memo said.

The latest actions by CMS are not earth-shaking on their own, said Steven Littlehale, chief innovation officer, Zimmet Healthcare, but are part and parcel of an evolving SFF program.

For background, CMS ranks all skilled nursing facilities based on deficiency scores from inspections and complaint surveys. Facilities with the highest scores become SFF candidates (5 to 30 per state, depending upon the number of SNFs in the state). State agencies select from the candidate pool to become SFFs considering factors like staffing, and the designated facilities that make the list receive intensified scrutiny and enforcement.

Littlehale said the factors that make a SNF a SFF candidate are objective whereas those that elevate a candidate to SFF status appear mostly subjective in nature.

CMS, he said, uses data for ranking all SNFs from their survey experience to create the SFF candidate list. However, survey outcomes vary considerably by geography.

Littlehale cited data that show the average number of health citations in the U.S. at 9.5 as of July 2025. But, as an example of the uneven nature of the process, CMS region 9 (San Francisco) averaged 16 citations and CMS region 4 (Atlanta) only 6. But he calls out two key points: “It’s not just the variation in total deficiencies, there is also significant variation in scope and severity,” in addition “within states there are notable variations between survey offices,” he said.

If SFFs do not act positively on quality, as measured by CMS’s survey and certification process, CMS may terminate Medicare/Medicaid participation for non-improving SFFs with triggers including:

• Immediate Jeopardy citations on two surveys

• Lack of improvement after 18–24 months

SFF status is a warning with clear outcomes: improve, graduate, or be removed, Littlehale said.

He noted that tweaks to the SFF program are ongoing, and some can have a major impact on the results of the SFF candidate pool in each state. For instance, due to the vagaries of the frequency of survey cycles in states, CMS changed their review process to reflect the last two survey cycles for standard surveys versus the previous three survey cycles.

“The change seems to come out of the blue, though many industry advocates were hoping for this evolution,” Littlehale said. In the graphic below, the change from two to three cycles has resulted in a larger-than-normal shift in candidate facilities being added or dropped from the candidate list (see the change from the top two timelines compared to the June to July measurement after CMS made the methodology change).

Park Place Live will continue to monitor CMS actions on SFF moving forward. Read the CMS memo at QSSAM-25-1-ALL. If you have news to share, or comments? Send to Patrick Connole at pconnole@parkplacelive.com.