Survey Readiness Is Shifting: What SNF Leaders Need to Know About the Top National Citations
Insights from Colleen Toebe, MSN, CWCN, RAC-MTA, RAC-MT, DNS MT – Vice President of Clinical Services
Skilled nursing facility leaders are navigating a survey environment that continues to intensify, and the most recent national citation trends tell an important story. While Infection Prevention and Control remains the leading national citation, followed by Accident Hazards/Supervision/Devices and Quality of Care, several areas moving higher in the rankings should capture the attention of every Administrator, DON, MDS Coordinator, department leader, and QAPI committee.
Top national citation areas include:
- F880 Infection Prevention and Control
- F689 Free of Accident Hazards/Supervision/Devices
- F812 Food Procurement, Storage, Preparation and Sanitary Service
- F684 Quality of Care
- F761 Labeling and Storage of Drugs and Biologicals
- F656 Develop and Implement Comprehensive Care Plan
- F842 Resident Records/Identifiable Information
- F755 Pharmacy Services, Procedures, Pharmacist and Records
- F677 ADL Care Provided for Dependent Residents
- F695 Respiratory/Tracheostomy Care and Suctioning
What is especially important for leaders is the shift in survey focus. Areas such as comprehensive care plans, medical records, respiratory care and services, and food procurement/sanitation are moving up in the national rankings. These are not isolated compliance issues. They reflect how well the facility’s systems are working every day, including:
- Care plans must clearly reflect resident-specific risks, needs, goals, and interventions.
- Medical records must support the care provided and demonstrate follow-through.
- Respiratory care and suctioning must be supported by competency, physician orders, monitoring, and documentation.
- Food procurement and sanitation must be consistently managed through infection prevention, dietary oversight, staff practices, and environmental monitoring.
These citation trends reinforce that surveyors are looking closely at the connection between assessment, MDS accuracy, care planning, physician orders, documentation, staff competency, and actual resident outcomes.
NEW! The June 26, 2026 CMS State Operations Manual Chapter 7 revisions further reinforce that survey readiness must be ongoing, not episodic.
CMS continues to emphasize continued compliance, prompt correction of deficiencies, and the expectation that facilities continuously monitor their own performance to sustain compliance. Facilities can no longer rely on “getting ready” shortly before survey. Leaders need to build year-round systems that connect QAPI, audits, documentation review, staff education, environmental rounds, infection prevention, pharmacy oversight, dining services, and resident-specific care delivery.
Key Chapter 7 updates that leaders need to understand include:
- Updated definitions, including abuse, immediate family, resident representative, neglect, instance of noncompliance, and substandard quality of care.
- Clarification that abuse may include mental abuse facilitated or enabled through technology.
- Additional guidance related to survey team composition, survey procedures, plans of correction, verification of correction, revisits, offsite paper reviews, off-hour surveys, civil penalties, IDR, and IIDR.
- Surveyor use of photographs as evidence during the survey process, including resident consent, privacy, secure storage, and chain of custody expectations.
- Continued focus on fraud, fraudulent activity, abuse reporting, resident safety, documentation integrity, and enforcement readiness.
Together, the national citation trends and Chapter 7 updates signal that more survey activity is ahead, and that surveyors will continue to look beyond policies and into the actual day-to-day systems that drive care outcomes.
Three Leadership Strategies for Preparedness
- Move from survey preparation to continuous compliance.
Use QAPI as the leadership engine for monitoring top citation areas. Review infection control, falls, food sanitation, care plans, medical records, pharmacy services, ADLs, and respiratory care through routine audits, trend review, action plans, and follow-up validation. - Audit the full resident care story.
For high-risk residents, validate that the MDS, baseline care plan, comprehensive care plan, physician orders, Kardex/point-of-care documentation, progress notes, therapy notes, dietary notes, pharmacy recommendations, and IDT interventions are aligned and tell one consistent story. - Prepare leaders and staff for an evidence-based survey process.
Train department leaders and frontline staff on what surveyors may observe, review, request, and photograph. Staff should understand abuse definitions, resident representative expectations, documentation standards, food sanitation practices, respiratory care expectations, infection control basics, and when to escalate concerns.
How Pathway Health Can Help
Pathway Health can assist SNF leaders in preparing for this changing survey landscape through practical, customized regulatory support, including:
- Mock Survey Reviews using CMS survey tools and the federally mandated survey process.
- QuickCHECK Mock Survey for a high-level review of compliance with top state and national citations or facility-identified focus areas.
- Focused Regulatory Reviews for high-risk areas such as infection prevention, accident prevention, food sanitation, care planning, medical records, pharmacy services, respiratory care, ADL documentation, and other survey-prone systems.
- Virtual Clinical System and Trend Reviews to evaluate clinical documentation, systems, and regulatory vulnerabilities.
- Regulatory Response and Plan of Correction Support, including survey recovery, IDR/IIDR support, Immediate Jeopardy removal, directed POC support, POC implementation, and leadership coaching.
- Customized education, tools, and resources to support staff competency, leadership oversight, QAPI follow-up, and sustainable compliance.
As survey activity continues to evolve, preparedness is more than knowing the top citations. It is understanding what those citations reveal about daily operations, resident outcomes, documentation, staff competency, and leadership oversight. Pathway Health brings insight, expertise, and knowledge to help leaders identify vulnerabilities, strengthen systems, and build a sustainable culture of compliance and quality.
Download the Leadership Survey Readiness Checklist >
