
You know the old adage—no one likes change! I remember years ago, attending a team-building session called “Who Moved My Cheese?” The book was written to help employees cope when change turns their world upside down. It shows, in practical terms, how to anticipate and prepare for change, overcome fear, envision success, and even enjoy the process. This summary of “Who Moved My Cheese?” by Spencer Johnson lays out these lessons clearly. So here we are again—CMS survey contingency planning has brought us a fresh round of updates, and we’re learning to adjust.
The latest twist comes from CMS itself. On October 1, 2025, it released a memo titled Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown. The memo briefly stated that CMS would identify functions that (a) are not affected by a Federal shutdown, (b) excepted functions that are to be continued (also called “essential functions”), and (c) other activities that are not legally authorized to be performed during a shutdown and must stop.
Fast forward to October 25, 2025, when a revised version was issued, QSO-26-01-ALL REVISED 2025-10-01. In the updated language under section (C), CMS now clarifies which survey activities are not legally permitted during a federal shutdown. As reported by Skilled Nursing News, this includes Medicare recertification surveys, initial surveys for new providers, and most complaint investigations—unless there is an immediate jeopardy situation.
But there’s a silver lining here. This pause gives us a rare opportunity to reset. With fewer surveys on the calendar, now is the perfect time to assess your community’s high-risk areas. Pull out that incident that led to a negative outcome—does it warrant an HPNC? Use QAPI meetings to dig into systemic issues and launch new PIPs. This is your moment to regroup, strengthen your practices, and prepare for what’s next. Thoughtful CMS survey contingency planning now can ease the pressure later.
Stay well and stay informed!

