On November 24, 2025, the Centers for Medicare and Medicaid Services (CMS) issued QSO-26-02, which outlines how states are to proceed now that the federal government has reopened. The memo notes that on November 12, 2025, Congress enacted Public Law 119-36, which provides a continuing resolution through January 30, 2026. The appropriation also gave retroactive authority back to October 1, 2025.
Throughout the memo, CMS answered several questions it has received from State Agencies on how to return to normal functions.
Some important responses include:
- All Survey, Enforcement, and Certification activities should resume to normal.
- Citations given during state licensure surveys cannot be cross-walked to federal F-tags if a state licensure survey was conducted during the shutdown.
- States are expected to issue all outstanding CMS-2567 held during the shutdown by December 12, 2025.
- States may adjust the exit date to the date of compliance in the system to either the date of the issuance of the CMS-2567 or the compliance date identified by the facility.
- States are directed to consult the CMS location to discuss this if there is an open enforcement cycle.
- If a facility submitted an appropriate Medicare enrollment application, met all Medicare requirements, was determined by the State to be in substantial compliance, and was recommended and approved by the Medicare Administrative Contractor (MAC), then the Medicare certification date can be retroactive to the date these requirements were met.
- Any surveys held during the shutdown may resume at this time. Some information may need to be updated, but States do not have to restart the survey.