CMS is tightening oversight of accrediting organizations, prompting hospital leaders to examine what the changes could mean for accreditation surveys and survey preparation.
On June 12, the agency published a final rule strengthening oversight of the nine accrediting organizations that survey more than 9,000 Medicare-participating providers annually for compliance with federal health and safety requirements.
The rule takes effect June 16, 2027, and includes several changes aimed at increasing consistency and reducing potential conflicts of interest in the accreditation process. Among the most significant shifts: Accrediting organizations will no longer be permitted to alert facilities shortly before a survey begins. CMS said some organizations had provided same-day notifications, occasionally within an hour of surveyor arrival.
The rule also places new restrictions on pre-survey consulting. Accrediting organizations will be prohibited from conducting mock surveys for providers they accredit before initial surveys, within 12 months of re-accreditation or in response to complaints they have received about a provider.
CMS said the changes are intended to strengthen oversight, align accreditation processes more closely with Medicare requirements and improve consistency across surveys.
Hospital executives with whom Becker’s spoke generally agreed that accreditation surveys should reflect day-to-day operations.
Becker’s connected with Alan Levine, chairman, president and CEO of Johnson City, Tenn.-based Ballad Health, and Ashley Carlucci, DNP, RN, chief nurse executive at Pittsburgh-based Allegheny Health Network, about what the changes could mean for health systems.
Mr. Levine said the elimination of advance alerts will not significantly affect Ballad Health’s approach to survey readiness, as it closely mirrors how state surveyors already operate.
“That change shouldn’t bother any system that tries to operate the right way every day, because we’re always subject to a state surveyor coming in,” he said.
Dr. Carlucci expressed similar sentiments with respect to Allegheny Health’s approach to survey preparedness.
“We strive to always be in that constant state of readiness,” she said. “We’re ready when anybody walks through the door, because this is what we do every day, and so our house is open no matter what, and we want to show the good work that we’re doing, regardless of the notification.”
The mock survey restrictions drew a more nuanced response from Mr. Levine, who said such exercises can play an important role in helping hospitals identify and address potential deficiencies.
“Historically, The Joint Commission’s perspective has been that they want you to be successful in the survey,” he said. “If you do a mock survey, they’ll do everything they can to identify what they would cite, and I’ve always viewed those as being very helpful. It’s not just about getting through a survey; it’s about making sure we are meeting the standards on everything.”
For Allegheny Health Network, the restrictions are unlikely to create significant disruption. Dr. Carlucci said the system already relies on internal teams rather than outside consultants to conduct mock surveys.
“As a network we’re lucky enough that we have those resources to be able to do that,” she said. “So we have expertise locally that then can come in and do those mock surveys at our different facilities, and they’re not the same everyday walk in the lines, where you kind of put your blinders on. They’re from our system, so they’re looking at all the things like regulatory [agencies] would be.”
She said the process has helped foster collaboration across facilities while allowing teams to identify and share best practices throughout the system.
Those reviews are typically led by quality and regulatory staff, with clinical and facilities experts participating depending on the focus of the survey, she said.
Mr. Levine said Ballad Health will continue conducting mock surveys using external experts, including former accreditation surveyors who now work as consultants.
“Whether The Joint Commission does it or former surveyors do it, there will always be the opportunity for hospitals to do mock surveys, and I think they should,” he said. “That’s no different from doing cybersecurity mock events or bomber drills. You always want to practice and learn, and when you do a drill, you apply what you learn.”
Mr. Levine, who previously served as Louisiana’s health secretary and led Florida’s Agency for Health Care Administration, welcomed the rule’s requirement that accrediting organization surveyors complete the same CMS training as state survey agency surveyors.
“I noted they’re going to standardize training, and that’s something I’ve seen as an issue in the past,” he said. “State surveyors have had different types of backgrounds and training than Joint Commission surveyors. That’s a good improvement.”
Mr. Levine said the mock survey restrictions also raise a broader question about the role of accreditation and oversight.
“Think about whether the goal is to ensure hospitals meet the standards for accreditation, or if the goal is to increase the number of hospitals you catch that are not in compliance,” he said. “Having led state healthcare agencies in Louisiana and Florida, my approach has always been that we need hospitals to be compliant, and to the degree we can provide information or best practices, that’s a positive thing.”
While the rule does not specifically address the sharing of best practices among hospitals, Mr. Levine said he hopes that aspect of the accreditation process continues.
He also said accrediting organization surveyors, including those from The Joint Commission, have historically shared lessons learned and best practices from other health systems during surveys, which he views as beneficial.
“If you prevent surveyors from doing that, I think that’s a missed opportunity,” Mr. Levine said.
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