Skilled nursing facilities enrolled in the SFF program must demonstrate systemic, sustained improvement immediately upon entry to avoid escalating enforcement remedies, including discretionary termination from federal funding.
REVISED: Revisions to the Special Focus Facility (SFF) Program
CMS will impose immediate sanctions on an SFF that fails to achieve and maintain significant improvement in correcting deficiencies on the first and each subsequent standard health, complaint and LSC/EP survey after a facility becomes an SFF. Additionally, enforcement sanctions will be of increasing severity for SFFs demonstrating continued noncompliance and failure to demonstrate good faith efforts to improve performance.
United States, Department of Health and Human Services, Centers for Medicare & Medicaid Services. “REVISED: Revisions to the Special Focus Facility (SFF) Program.” QSO-23-01-NH REVISED, 28 Jan. 2026, www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/revisions-special-focus-facility-sff-program.
QSO Memo 23-01-NH (Revised): January 28, 2026
TECHNICAL CORRECTIONS: September 27, 2023
PUBLISHED: October 21, 2022
⚠️ BREAKING: CMS shifting Special Focus selection to emphasize falls over staffing
In its memo to state survey agency directors Wednesday, CMS officials said they were asking states to begin considering falls — in addition to survey scores — partly in response to watchdog calls for better scrutiny of falls prevention and reporting. Updates to the directive remove language that previously directed state teams to consider staffing ratings or ratios, given staffing’s “importance of staffing and its relationship to quality.”
The change is a major departure from CMS, which had increasingly aligned staffing metrics – more readily available with the advent and expansion of Payroll Based Journal reporting – with quality measurement and enforcement priorities.
— McKnight’s Long-Term Care News, January 28, 2026
CMS Announces Immediate, Aggressive Enforcement for Special Focus Facilities (SFF) Participants
CMS will use escalating penalties for violations, including considering facilities with citations for dangerous violations in two successive inspections for termination from Medicare and/or Medicaid funding.
CMS has increased the requirements that an SFF must meet to be successful and graduate from the program. And for those SFFs that graduate from the program, CMS will continue close scrutiny of the facility for at least three years.
— LeadingAge Minnesota, October 25, 2022
Feds ramp up nursing home sanctions for poor care performance
Industry advocates pushed back at the plan for escalated enforcement. Increased citations and penalties have historically not made a dent in changing poor performers, the American Health Care Association and National Center for Assisted Living said.
LeadingAge, meanwhile, reiterated its support of federal initiatives to improve care at poorly performing nursing homes, supporting closures of those that do not improve. It also called for an “all-of-government approach to finding solutions that will address the chronic staffing challenge.”
— McKnight’s Long-Term Care News, October 24, 2022
CMS toughens stance on worst-performing nursing homes
The agency said it will toughen requirements for completion of the program, increase enforcement actions and lengthen the monitoring period for facilities that enter the program. Showing its commitment to staff improvement, CMS also called on states to consider a facility’s staffing level in determining which facilities enter the SFF Program.
CMS described the changes as a way to “increase accountability of bad actors in the nursing home industry.” There are currently 88 nursing homes in the SFF program, with approximately 400 more on the candidate list.
— McKnight’s Long-Term Care News, October 21, 2022
CMS to ‘Crack Down’ on Troubled Nursing Homes Through Special Focus Facility Program Changes
Specifically, the Centers for Medicare & Medicaid Services (CMS) is making completion requirements more challenging and increasing enforcement actions if SNFs fail to show improvement, according to a statement issued by the federal agency on Friday.
Criteria for successful completion of the SFF program will now have a threshold that prevents a facility from exiting based on total number of deficiencies, according to CMS. There will be no more “graduating” from the program’s enhanced scrutiny without showing that a facility has made systemic improvements in quality.
— Skilled Nursing News, October 21, 2022
