SNF Insights guide

CMS’s High Performing Icon and the Risk-Based Survey, Explained

On October 8, 2026 CMS put a gold trophy icon on the Care Compare profile of every nursing home that qualifies for its new Risk-Based Survey, a shorter inspection. By our count 1,699 of 14,690 homes carry it (11.6%).

Updated October 2026 · Sources: CMS memo QSO-26-14-NH (revised September 29, 2026); statements as linked; CMS Provider Information, October 2026

The icon means a home qualifies for a shorter inspection

CMS calls it the High Performing Facility Icon. It is tied to the Risk-Based Survey (RBS), which the memo describes as “a modified form of the LTCSP,” the standard long-term care survey process, that is “conducted in roughly half the time with fewer total surveyors” and reviews “a smaller number of residents.” CMS piloted it from 2023 in 22 states and over 100 facilities and began using it nationwide on September 8, 2026.

CMS’s stated reason is workload: its survey budget has “not been increased since 2015,” while complaint workload rose by over 20%. CMS also says qualifying for the shorter survey “indicates a higher level of performance,” and that is the claim the debate below is about.

Eleven requirements; the 5-star overall rating stops most homes

A home must meet all eleven. Seven can be checked from CMS’s published data; four depend on audits and coding reviews CMS does not publish home by home, which is why a home can meet every visible requirement and still be left off.

RequirementTo qualifyPublic data?
Overall star rating5 starsYes
Staffing star rating3 stars or moreYes
Harm, Immediate Jeopardy or substandard-quality-of-care citationsNone in the last survey cycle (last standard survey, plus complaint surveys in the past year)Yes
Standard surveyWithin the last 18 monthsYes
Health inspection scoreBetter than the state’s medianYes
Change of ownershipNone since the last surveyYes, from PECOS
Special Focus Facility candidateNot a candidateYes
Staffing waiverNoneNo
Payroll-Based Journal staffing auditNot failedNo
MDS assessment auditNot failedNo
New schizophrenia codingFewer than two residents aged 65+ newly coded after admissionNo

QSO-26-14-NH, Appendix A. States can also skip the shorter survey for a home with a serious complaint pending or found (Appendix C).

The overall rating is the hardest test: CMS’s memo counts 78% of homes failing that requirement. The overall rating starts from the health inspection star and gains a star only for a 5-star staffing or a 5-star quality measure rating; in our check against every rated home in the October file, 4 stars on staffing adds nothing. So a 5-star overall rating usually needs a strong inspection record first. Of the 3,011 homes rated 5 stars overall in October, 1,699 carry the icon.

The list is refreshed quarterly from earlier ratings

CMS sends state survey agencies a qualified list at the end of each calendar quarter (March, June, September, December). A home stays eligible for “six months after the SA receives the list” unless it is disqualified sooner, and the icon “will remain on the nursing home’s profile page until the facility is no longer eligible.” Because the list is built from ratings a few months old, a home that reaches 5 stars today appears only on a later list. A survey done under the shorter process is footnoted on Care Compare, on the inspection report (Form CMS-2567) and in CMS’s data files.

October 2026Homes with the iconShare
United States1,699 of 14,69011.6%
Most homes: California159 of 1,16513.6%
Highest share (20+ homes): Nevada15 of 6623%
Then Minnesota, Iowa67 of 338; 75 of 38720%; 19%
None: Alabama0 of 2240%

SNF Insights count from CMS’s Provider Information file of October 8, 2026.

Supporters say it rewards performance

“At CMS, we are continually looking for ways to recognize excellence for top performers and to encourage lower performers to improve.”
Dr. Mehmet Oz, CMS Administrator, July 16, 2026, Skilled Nursing News
“Highlighting the qualifying nursing homes on Care Compare is a meaningful and positive recognition beyond the traditional star ratings for high performers.”
Katie Smith Sloan, President and CEO, LeadingAge, July 16, 2026, Skilled Nursing News
“This initiative upholds accountability while further incentivizing quality improvement by recognizing high-performing facilities.”
Clif Porter, President and CEO, AHCA/NCAL, July 16, 2026, Skilled Nursing News

Operators interviewed by Skilled Nursing News in August were positive, with caveats. LeadingAge, while supportive, also named consistency in citation and enforcement as a continuing concern.

“a welcome next step along the journey of rewarding performance instead of just focusing on penalties”
Brian Ellsworth, Health Dimensions Group, August 14, 2026, Skilled Nursing News
“Maybe the facility in your town that has the icon doesn’t provide dementia care or doesn’t provide some high acuity care that your family member needs.”
Michelle Stuercke, Transitional Care Management, August 14, 2026, Skilled Nursing News

Critics say it means less inspection, not better care

“these gold trophies should serve as a warning that a facility has not been vigorously inspected, not as a signal of good care, safety, or dignity”
Long Term Care Community Coalition, July 23, 2026, nursinghome411.org
“quality of care and quality of life problems will be missed”
Toby S. Edelman, Center for Medicare Advocacy, July 28, 2026, medicareadvocacy.org
“it simply means the nursing home meets the qualifications for a program CMS has created to address survey funding concerns”
Consumer Voice, July 2026, statement (PDF)

Consumer Voice also tested how stable qualification is. Applying seven of the eleven requirements to January 2024 data, it found 1,769 of 14,906 homes would have qualified, and only 52% still did 13 months later; losing the 5-star overall rating accounted for 74% of the drop-outs (data brief, September 8, 2026). Its brief also says the shorter survey keeps infection control as the only required facility task.

What the icon does and does not tell you

The icon says a home met CMS’s requirements on recent ratings and qualifies for a shorter inspection. Most of what it reflects is already on the home’s profile (the stars, the inspection record, the staffing data), and those are worth reading directly. The exception is the four checks CMS does not publish; the icon is the only public sign that a home passed them. A home without the icon may have missed a single requirement, such as a standard survey more than 18 months old.

SNF Insights flags the homes that carry the icon on facility pages, chain rosters and the market map.

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