Top 5 Emergency Preparedness Violations Surveyors Are Looking For, and What Changed in 2025

Keeping your facility compliant isn’t just about passing surveys—it’s about protecting residents when emergencies strike. In 2025, CMS surveyors are paying even closer attention to emergency preparedness, documentation, compliance & staff training. With the revised F-tag list released in April 2025, deficiencies are now tracked and reported differently, and inspection results are posted much faster than before. That means less time to react—and more risk if you’re not prepared.

According to CMS Quality, Certification and Oversight Reports (QCOR), the same problem areas continue to surface year after year. Infection control, accident hazards, and food safety violations remain the most common citations nationwide. Let's look at the top five compliance hotspots - and how to stay off the list.

1) Infection Prevention & Control (F880)

• Staff not following proper hand hygiene
• Incorrect or inconsistent use of PPE
• Isolation precautions not enforced properly
• Cross-contamination in resident care areas
  

📌 Pro Tip: Reinforce the basics—hand hygiene audits, PPE training refreshers, and environmental cleaning logs are among the first things surveyors check

2) Accident Hazards & Supervision (F689)

CMS defines F689 as keeping residents “free from accident hazards.” In practice, surveyors most often cite:

• Falls caused by lack of supervision or environmental hazards
• Clutter or tripping hazards in hallways or resident rooms
• Poorly maintained equipment or assistive devices
• Unsafe practices during transfers and mobility assistance

📌 Pro Tip: Conduct weekly “environmental rounds” to spot hazards. A clean, uncluttered space is your best defense against this tag.

3) Food Procurement, Storage & Sanitation (F812)

Food safety citations consistently rank in the top three nationwide. Most are tied to kitchen practices—like improper sanitization, poor temperature control, or expired items—but this tag also applies to emergency food and water reserves.

While CMS doesn’t mandate a uniform standard for supply levels, facilities are expected to follow emergency preparedness guidelines, which commonly recommend at least three days of food and water per resident. Surveyors will check that reserves are:

• Safe from contamination
• Properly labeled and rotated
• Not expired or stored in unsafe conditions

📌 Pro Tip: Build emergency food and water checks into your dietary manager’s routine. Rotate stock as needed and document the process—10 year food and water options eliminate most expiration headaches.

4) Care Plans, Documentation & Training (F684, F656, and EP Rule)

Emergency preparedness isn’t a binder on the shelf—it must be woven into care delivery. Facilities are cited when plans are generic, outdated, or not adjusted for census and resident needs. The most common gaps include:

• Care plans that don’t address evacuation or shelter-in-place needs
• Outdated or missing documentation of staff drills
• Incomplete after-action reports following training exercises
• Lack of proof that plans are reviewed and updated

📌 Pro Tip: Treat emergency preparedness like an ongoing QAPI project. Document every drill, update, and plan review. If it’s not on paper, surveyors will assume it didn’t happen.

5) Training & Testing Gaps

The CMS Emergency Preparedness Rule requires facilities to:

• Conduct two drills per year (one full-scale, one tabletop)
• Involve staff across departments
• Evaluate performance and update the plan

The single biggest citation in this category? Failure to document participation and follow-up. Facilities may run the drill but skip the paperwork, leaving them exposed during surveys.

📌 Pro Tip: Assign one person per drill as “scribe.” Collect attendance sheets, photos, and after-action notes. These simple artifacts often mean the difference between compliance and a deficiency.

The 2025 Update: What Changed

In April 2025, CMS released a revised F-tag list. While the underlying rules haven’t changed, the way surveyors categorize and post deficiencies has. Inspections are now published to the public almost immediately—leaving little room to “fix quietly” before families or referral partners see them. For administrators, this accelerates the reputational risk of even minor citations.

Staying Ahead of Surveyors

• Align with the “3-day supply” standard for food and water as a minimum
• Conduct regular environmental rounds to prevent falls and hazards
• Review and update emergency plans quarterly
• Train, drill, and document relentlessly