Timeliness. The word seems to have a lot of different meanings to regulators when it comes to informing a skilled nursing facility (SNF) and therefore the public on the results of a survey, be it negative, or a more positive update on corrective measures via a CMS-2567 Statement of Deficiencies form. These delays in announcing survey results can cause great disruption and even loss of business or worse for a SNF, and its perception in the greater community.

For example, if I am a SNF surveyed on a Monday, and the surveyors exit on Wednesday, there could be a waiting period stretching to 30, 60, or 90 days, or more. This leaves a SNF in limbo and in peril if hit with a Civil Money Penalty (CMP) that accrues thousands and thousands of dollars in fines if not corrected. The problem could have been addressed poste haste, instead it lingers on and on.

The SNF is in the dark. How can you correct something you are not informed about for an average of 30 days after the surveyors leave?

This leaves the basic question. How soon after a survey should a facility expect its 2567?

Not So Simple

Much has changed in the regulatory landscape, but at the same time, so very little has. The Centers for Medicare and Medicaid Services (CMS) has modernized the latter portion of the reporting process, accelerating when survey deficiencies become visible to the public. But the real delays - the ones that affect operators, residents, referrals, lenders, and survey predictability - remain firmly rooted upstream.

Changed

On June 18, 2025, CMS released QSO-25-19-All, establishing a faster public-release policy for the CMS-2567 form. Under this policy, deficiency findings will be displayed on Care Compare within 14 days of the provider’s receipt of the 2567. Previously, public posting could be delayed up to 90 days, depending on Plan of Care submission, administrative review, or system lag.

CMS states that they are “committed to the transparency of quality of care findings, so that patients, residents, and their families can make informed health care decisions.”

Not Changed

What has not changed is everything that happens before the provider receives the 2567, surveyor drafting, supervisory review, State Survey Agency quality assurance, potential CMS Regional Office review, and the timing of data upload into the iQIES portal.

These steps continue to cause the greatest delays, with wide variation between states.

State Survey Data Entry Delays (2025)

(source https://qcor.cms.gov/)

Despite CMS’s commitment to transparency to consumers, 72 percent of surveys are not entered into iQIES within 30 days, with the average delay exceeding 100 days in some states. This undermines transparency and creates real-world problems for all.

If a CMP is imposed against a nursing home, they are financially accountable from the date of survey until substantial compliance is reached, even if months pass before the facility is notified. In addition, the delay in notification means stakeholders, such as lenders, must make decisions without current regulatory information, increasing perceived risk and reducing the likelihood of favorable terms.

CMS’s new 14-day posting requirement modernizes the final stage of the survey process. However, the true bottleneck—the time from survey completion to issuance of the 2567—remains unchanged and widely variable. Until the various upstream delays are addressed, transparency and operational predictability will remain limited.

Questions or comments? Contact Patrick Connole at pconnole@parkplacelive.com.