The latest: On October 31, 2025, CMS issued a second revision to QSO-26-01 ALL REVISED. This is the memo outlining contingency plans for CMS and state survey agency activities during the federal government shutdown.

• In this revision CMS added an additional opportunity for a revisit throughout the federal government shutdown. In addition to revisits to prevent statutorily-mandated (three-month) denial of payment for new admissions, CMS is now allowing revisits for discretionary denial of payments that are in effect.

For context: The memo was originally issued on October 1, 2025. The first revision was issued on October 21, 2205.

• The memo established that the activities which are not allowed throughout the shutdown, are not legally authorized to be performed.

• Review this table from AHCA outlining the contents of the memo. It breaks down the functions as follows:
  • Survey and Certification Activities Not Affected by a Federal Government Shutdown
  • Excepted (or Essential) Medicare Functions During the Shutdown (those activities related to the safety of human life or protection of property)
  • Activities Prohibited During a Federal Government Shutdown

Additional resources

• CMS Issues Updated Memo to Outline Contingency Plans During Government Shutdown