The current federal shut down has impacted most CMS Medicare Certification and Survey Activities. CMS issued a revised memo dated October 31, 2025 identifying those activities not deemed “essential functions” for protecting beneficiaries against immediate dangers to life and health. Such activities are being paused during the government shutdown and are summarized below.
Survey and Certification Activities Prohibited During Federal Government Shutdown
- Standard Surveys-No Medicare-funded recertification surveys shall be performed.
- Certain Revisit Surveys-The only authorized revisits are those necessary 1) to ensure that immediate jeopardy or actual patient/resident harm has been addressed, 2) to prevent termination of Medicare participation within 45 days of the termination date, or 3) prevent mandatory denial of payment for new admissions within 15 days of imposition.
- Initial Surveys-No Medicare initial surveys shall be performed.
- Initial Certification (Including via Deemed Status)-States shall not conduct any initial surveys or take any action on initial certification kits.
- Certain Complaint Investigations-No Medicare complaint investigations should be performed, except those alleging immediate jeopardy or actual harm to individuals.
- MDS or OASIS-No minimum data set (MDS) or OASIS activities should be conducted except those necessary to maintain provider reporting.
- Informal Dispute Resolutions (IDR)-No IDRs should be conducted unless performed pursuant to specified excepted complaint investigations.
- Surveyor Trainings-No training activities for which there is an expectation of federal reimbursement is permitted.
- Processing of Certification Actions-Routine Medicare provider certification activities such as initial certifications, changes of ownership, and changes of location will not be completed.
- New CMP-Funded Improvement Projects-No new improvement projects funded by collected civil monetary penalty funds should be implemented unless approval has already been granted by CMS.
Per the current scenario, health systems should anticipate delays in approval of certification tasks including issuance of new CCNs for newly enrolled facilities. Such delays will result in an extended period of time during which facilities seeking initial certification are not able to bill Medicare causing prolonged cash flow interruption. In turn, Medicaid enrollment, Medicare Advantage payer credentialing and contracting with many nongovernmental payers is dependent upon having proof of Medicare certification and a CCN. As such, these delays will impact reimbursement eligibility and cash flow far beyond traditional Medicare. Health systems are urged to evaluate its pending and future development projects to assess the potential impact these certification delays will have on business operations to determine whether additional budgeting considerations may be necessary.
Published November 4, 2025
