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Risk-based surveys won't end the surveyor lottery, and most facilities won't get the faster track
Skilled Nursing News reported on August 21, 2026 that Lisa Chubb, chief nursing officer at New Jersey-based Venza Care, used the RETHINK Forum to tell operators how to prepare for CMS's risk-based survey model. Her central point was that results will still depend on which surveyor walks in. The article cites CMS data showing only 12% of facilities qualify. Roughly 1,400 are locked out because their states are behind on surveys, and in Alabama none qualify. Chubb also said about 85% of surveys are complaint surveys and that the federal survey budget has been virtually flat since 2015. Her practical advice centres on a readiness binder and a continuously updated CMS-802 resident roster.
Will my facility qualify for a risk-based survey?
Probably not. The article, citing CMS data, says only 12% of facilities qualify, and eligibility depends partly on whether your state is keeping up with its survey schedule.
That makes eligibility partly outside your control. A building can do everything right and still be excluded because its state agency is behind. Venza operates in Alabama, so its leadership is directly exposed to the zero-qualifier outcome.
The figures also don't sit together neatly. If 12% qualify, the 1,400 locked-out facilities look like a subset of the excluded group, not all of it. The article's account of the qualifying conditions is thin too, mentioning star ratings and, oddly, schizophrenia diagnoses. Get the criteria from CMS itself rather than from a secondary summary.
Does a risk-based survey reduce surveyor subjectivity?
No. Chubb says outcomes still vary by surveyor, and the sector's praise for the model concerns shorter inspection lags and rewards for top-rated facilities, not consistency.
The variable you can control is how easily a surveyor finds what they need. Chubb's warning is that EHRs look different at every organisation, and a surveyor who can't see records may suspect concealment. Then, in her words, "the gloves are off." Mergers and acquisitions make this worse, because a recently acquired building may run on a different record setup from the rest of the group.
Here is an angle the coverage skips. In many buildings, the person who knows the click path is the DON or ADON. If that person leaves, so does the knowledge. A written binder is partly a hedge against nursing-leadership turnover. That reading is ours, not Chubb's. We have covered nurse leadership under scrutiny before, and this is the paperwork side of it.
What belongs in a survey-readiness binder?
Current entrance requirements, step-by-step EHR click-path instructions for surveyors, and a CMS-802 roster kept continuously updated. Keep the data targeted rather than overwhelming, and mind legal protections.
The CMS-802 lists current residents and maps clinical categories: diagnoses, treatments, high-risk medications, pressure ulcers, facility-acquired wounds, and nutrition and weight. Chubb warns against flooding surveyors with data and says leaders should respect attorney-client confidentiality and quality-assurance protections. Someone, ideally with counsel, has to decide in advance what goes in the binder and what stays out.
How much weight should I put on the numbers?
Treat them as one operator's framing. The 85% complaint-survey share and the flat budget since 2015 are attributed to Chubb, and the article text we saw cites no source document for either.
Ask who defines "complaint survey" and who counted. "Virtually flat" against inflation implies a real-terms cut, but no size is given. The direction is plausible. The magnitude is unquantified. Chubb also said CMS is listening and open to what the industry needs, which is her read of the agency and not a measured outcome.
Before you spend on readiness, put three questions to the people selling it to you. Ask your EHR vendor whether it can provision documented, read-only surveyor access, and how it handles records after an acquisition. Ask your state agency where you sit on its survey backlog. Ask any consultant what they measure to show their programme works.
Frequently asked questions
How do I find out whether we're in the risk-based model?
Start with the CMS data the article draws on, then ask your state survey agency. Eligibility reportedly varies sharply by state.
Should we give surveyors all our data?
No. Chubb advises against overwhelming them and says to stay within confidentiality and quality-assurance protections.
Who should own the CMS-802?
The article doesn't say. It only says the document must be kept continuously updated, so name an owner and a backup.
Sources: Skilled Nursing News, "How Nursing Homes Can Prepare for the Risk-Based Survey Era Amid Lingering Underfunding and Surveyor Subjectivity," by Amy Stulick, August 21, 2026.