CMS doesn’t issue a 300+ page update to the State Operations Manual (SOM) because it wants providers to read more. CMS issues updates like QSO-26-03-NH (January 30, 2026) because it wants the system to behave differently, faster, tighter, and with less tolerance for drift. This revisions go into effect March 30th, 2026.

The challenge for providers is obvious: most operators don’t have the time (or appetite) to translate a 310-page memo into daily practice. But the opportunity is just as real: organizations that convert regulatory change into repeatable habits and can prove it with credible evidence will be better positioned during surveys, complaint investigations, revisits, and enforcement decisions.

This update focuses on two areas that directly shape outcomes:

Chapter 5: complaint handling, IJ recalibration, off-site investigations, revisits, enforcement pathways, CMP use, and the CMP Reinvestment Program.

Chapter 7: survey team guidance and the mechanics of how surveys are conducted, including off-hours expectations.

Below is the practical translation: what has changed, why it matters, and how leaders can turn it into forward-looking preparedness—without overwhelming their teams.

Why this matters right now

For most providers, risk isn’t created in court and it isn’t created in a survey conference room. Risk is created in the space between policies and practice, where handoffs happen, where staffing is thin, where weekends run differently than weekdays, and where documentation becomes the only “voice” left after the fact.

QSO-26-03-NH is CMS signaling: we are tightening how we evaluate seriousness, how quickly we respond to complaints, and how we validate correction.

That can feel like pressure. It can also be a catalyst—an opportunity to strengthen systems, reduce surprises, and build more consistent practice across shifts.

What changed in Chapters 5 and 7

1) Complaint handling and IJ emphasis are sharper

CMS recalibrates complaint handling and Immediate Jeopardy (IJ) triage, reinforcing urgency, structure, and consistency in how concerns are prioritized and investigated.

Operationally important updates include:

Off-site complaint investigations are rare and require CMS pre-approval.

IJ prioritization examples explicitly include scenarios involving discharge to unsafe/unsupported settings when resident needs cannot be met in the receiving setting.

Complaint letters shift away from “substantiated/unsubstantiated” language toward whether noncompliance was identified.

Why this matters: High-risk findings are increasingly tied to what leaders knew, documented, escalated, and did next especially around transitions, supervision, and communication.

2) Survey readiness now includes off-hours reality

Chapter 7 guidance reinforces that surveys are not designed around weekday leadership rhythms. CMS emphasizes off-hours and weekend survey starts as part of standard practice.

Why this matters: Many organizations are “survey ready” when their strongest leaders and most seasoned staff are present. But systems don’t fail only during business hours. Off-hours readiness is where operational consistency and culture becomes visible.

3) Plans of Correction and revisits place more weight on proof

CMS reinforces that POCs must be submitted within 10 calendar days and that failure to submit an acceptable POC can trigger immediate remedies.

CMS also sharpens revisit expectations and emphasizes that surveyors should use credible evidence, not just the POC narrative, when setting the compliance date.

Why this matters: A “good POC” is no longer enough. Organizations need to be prepared to show sustained implementation—through documentation, training, monitoring, and leadership oversight.

4) CMP strategy and CMP reinvestment are more operationally relevant

Chapter 5 updates include clarification around CMP use and the CMP Reinvestment Program, including allowable vs. non-allowable uses and transparency expectations.

Why this matters: CMPs aren’t just penalties—they’re part of an enforcement and improvement ecosystem. Organizations that understand this posture and can demonstrate real improvement planning are better positioned than those treating CMPs as unavoidable cost.

The hidden theme: CMS is rewarding operational discipline

What QSO-26-03-NH really does is increase the value of discipline:

discipline in investigation and follow-through

discipline in documentation

discipline in corrective action

discipline in proof

That discipline becomes the difference between:
“We fixed it” and “We can show you we fixed it.”

This is where providers can turn challenge into opportunity by building practices that do not depend on one standout leader or one strong building, but hold steady across shifts, departments, and locations.

 Practical implementation tools you can use right now

Most teams don’t need another 20-page summary they need a few repeatable prompts that turn a CMS memo into daily practice. Here are two quick tools we recommend building into your leadership routine right away:

Tool 1: Chapter 5 & 7 “What Changed” Leadership Snapshot

Use this as a standing agenda item for your next leadership meeting (10 minutes). The goal is alignment not memorization.

What changed that affects our pace? (complaints, IJ-level concerns, revisits)

What changed that affects what we must prove? (POCs, monitoring, compliance dates)

Where are we weakest off-hours/weekends? (coverage, escalation, documentation, family communication)

What is one operational habit we will tighten this month? (documentation, handoffs, investigations, audits, training)

Tool 2: “POC as Proof” Checklist

Treat every Plan of Correction as the start of an evidence file not a document you write once and hope holds.

A defensible POC approach consistently includes:

Immediate corrective action for affected residents

Identification of the at-risk population (not just the one resident)

System-level fixes to prevent recurrence

Training + competency reinforcement (who, when, and how verified)

Monitoring/audits with cadence + named accountability

Documentation that supports the claimed compliance date (so the date is defensible)

If you can produce these elements consistently, you reduce repeat findings and shorten revisit exposure not by luck, but by design.

How Adelman Firm can help

At Adelman Firm, we help providers translate regulatory change into practical execution without overwhelming already-busy teams. Our focus is on education, implementation, and defensible follow-through, especially in the areas that most often drive enforcement risk.

We support organizations through:

Plan of Correction strategy and review: operationally realistic POCs paired with the monitoring and evidence needed to support the compliance date

Education, training, and webinars: short, targeted sessions for executive directors, administrators, DONs, and department leads on what changed in Chapters 5 and 7 and what surveyors will expect to see

Response strategy when issues arise: guidance on complaints, revisits, enforcement exposure, CMP implications, and documentation alignment in a way that protects operations and strengthens defensibility

Leadership readiness support: practical coaching to reduce process drift, strengthen consistency across shifts, and build repeatable habits survey teams can observe and validate

If your team would benefit from a focused training session on these updates paired with practical POC support and response planning, we’re happy to help you build a plan that’s sustainable, operationally grounded, and defensible. Reach out to us for a one-on-one conversation.