CMS-2567 Statement of Deficiencies and Plan of Correction

The CMS-2567 Statement of Deficiencies and Plan of Correction is the federal form that records every regulatory violation found during a Medicare or Medicaid survey and captures the facility’s written response to each one. Surveyors fill in the left column with findings; the facility fills in the right column with its Plan of Correction. A completed CMS-2567 has 10 calendar days on the clock from the day the facility receives it, and what the facility writes in that right-hand column determines whether it faces a directed correction, civil money penalties, denied admissions, or termination from Medicare and Medicaid altogether.

The form applies to nursing homes, hospitals, critical access hospitals, home health agencies, and other certified providers. Most of the operational detail below reflects the long-term care context, where the CMS-2567 is used most heavily and where enforcement remedies are most fully spelled out in regulation.

How to Read a CMS-2567

The form runs in two parallel columns. On the left, the Statement of Deficiencies lists each finding: the federal regulation violated, the tag identifier, and the factual evidence gathered through observation, interviews, and record review. Federal regulation requires that these findings be “adequately documented,” including any response from the facility.1eCFR. 42 CFR 488.18 – Documentation of Findings The right column stays blank until the facility fills in its Plan of Correction, so each finding sits directly next to its proposed fix.

Surveyors tag each citation. F-Tags cover the long-term care requirements — resident rights, quality of care, pharmacy services, infection control, and the rest of the Conditions of Participation. K-Tags cover the Life Safety Code, meaning fire safety and building standards. A blocked fire exit gets a K-Tag; a missed medication pass gets an F-Tag.

Scope and Severity

Every citation is placed on a grid that combines how serious the problem is with how widespread it is.2Centers for Medicare & Medicaid Services (CMS). SFF Scoring Methodology Severity has four bands:

  • Levels A, B, C — no actual harm, potential for minimal harm. Noted but rarely trigger penalties on their own.
  • Levels D, E, F — no actual harm, but potential for more than minimal harm. Enforcement remedies typically start here.
  • Levels G, H, I — actual harm short of immediate jeopardy. A resident was hurt.
  • Levels J, K, L — immediate jeopardy. Noncompliance has caused or is likely to cause serious injury, serious impairment, or death.

Within each band, scope is rated isolated, pattern, or widespread. An L citation, widespread immediate jeopardy, is the worst finding a facility can receive.

Immediate jeopardy is the classification that changes the timeline. Surveyors must confirm three things to cite it: the facility violated a federal requirement, the violation caused or is likely to cause a serious adverse outcome, and immediate corrective action is needed.3Centers for Medicare & Medicaid Services. State Operations Manual Appendix Q – Core Guidelines for Determining Immediate Jeopardy Harm does not have to have already happened; if it is likely, that is enough.

Writing the Plan of Correction

The Plan of Correction is not a promise to do better. It is a structured document that has to address specific elements for every cited deficiency.4Centers for Medicare & Medicaid Services. Survey and Cert Letter 17-34 – New Guidance for Formatting Plans of Corrections For each citation, the plan must describe:

  • What corrective action was taken for the specific residents identified in the survey findings.
  • How the facility will identify other residents or areas potentially affected by the same problem, since one citation often points to a systemic issue.
  • What systemic changes — revised policies, training, changes in care delivery — will prevent recurrence.
  • How ongoing compliance will be monitored, through audits, quality assurance activities, or other oversight.
  • Who is responsible for implementation and a specific completion date.

An authorized representative — usually the administrator or director of nursing — must sign the first page of the CMS-2567 to accept responsibility for the plan. A missing signature can get the plan rejected, which restarts the clock on enforcement.

The 10-Day Deadline

Facilities have 10 calendar days from receipt of the Statement of Deficiencies to submit a completed Plan of Correction. That window runs through weekends and holidays without pause.5Centers for Medicare & Medicaid Services. State Operations Manual – Exhibit 139 Model Letter to Provider Missing it, or submitting a plan the state or CMS finds inadequate, can trigger rejection and accelerate enforcement.

Most long-term care facilities file electronically. As of July 2025, CMS moved its electronic Plan of Correction system into the Internet Quality Improvement and Evaluation System (iQIES).6QIES Technical Support Office. ePOC Launch in iQIES for Nursing Homes July 14, 2025 Electronic submission is encouraged but not mandatory; facilities that do not use it submit paper plans to the state survey agency.

When the plan comes in, the reviewing agency decides whether the proposed actions are sufficient. If so, it schedules a revisit. For substandard quality of care, actual harm, or unresolved immediate jeopardy, an on-site revisit is required.7Centers for Medicare & Medicaid Services (CMS). LTCSP Interim Paper-Based Onsite Revisit Instructions For lower-level findings, the agency may accept documentary evidence — invoices, training rosters, resident interviews — in place of a second visit. If the plan is deemed insufficient, the facility must revise and resubmit, and that back-and-forth compresses the compliance timeline.

When Immediate Jeopardy Is Cited

If a survey cites immediate jeopardy and the facility does not resolve it before surveyors leave, everything speeds up. The facility is placed on a 23-calendar-day termination track. The Plan of Correction must reach the CMS Regional Office within 5 calendar days of notice, half the usual window. If the jeopardy is not removed and compliance restored within 23 days, the provider agreement can be terminated.8eCFR. 42 CFR 489.53 – Termination by CMS

Challenging a Citation

A facility that believes a finding is wrong can request Informal Dispute Resolution (IDR). States must offer IDR for state-conducted surveys; CMS provides it for federal surveys.9eCFR. 42 CFR 488.331 – Informal Dispute Resolution The request has to be made within the same 10-calendar-day window as the Plan of Correction. This is the trap: requesting IDR does not pause the 10-day deadline, and it does not delay any enforcement action already underway. Both tracks have to move at once.

If IDR succeeds in showing the deficiency should not have been cited, the citation is removed from the Statement of Deficiencies and any enforcement action imposed solely because of it is rescinded.

When CMS imposes a civil money penalty that will be placed in escrow, the facility is also entitled to Independent Informal Dispute Resolution (IIDR), run by an entity with no conflict of interest.10eCFR. 42 CFR 488.431 – Civil Money Penalties Imposed by CMS and Independent Informal Dispute Resolution The facility must request IIDR in writing within 10 days of receiving CMS’s offer. IIDR must be completed within 60 days, produce a written record, and notify involved residents or their representatives so they can submit comments. A facility cannot use both IDR and IIDR for the same citation from the same survey unless the standard IDR finished before the penalty was imposed.

Neither process replaces a formal appeal. Facilities keep the right to pursue administrative appeals of citations or penalties regardless of what happens in IDR or IIDR.

What CMS Can Do to a Noncompliant Facility

Federal regulations sort enforcement remedies into three escalating categories.11eCFR. 42 CFR 488.408 – Remedies for Noncompliance

  • Category 1 covers isolated or patterned no-harm deficiencies with potential for more than minimal harm. Remedies include a directed plan of correction, state monitoring, or directed in-service training.
  • Category 2 covers widespread no-harm findings and any deficiency causing actual harm short of immediate jeopardy. Remedies include denial of payment for new admissions and civil money penalties.
  • Category 3 covers immediate jeopardy. CMS must impose temporary management or terminate the provider agreement, and may also impose civil money penalties.

Civil Money Penalties

CMS adjusts penalty amounts each year for inflation. Under the January 2026 adjustment, the ranges for skilled nursing facilities are:12Federal Register. Annual Civil Monetary Penalties Inflation Adjustment

  • Category 2 per-day: $136 to $8,211 per day of noncompliance
  • Category 2 per-instance: $2,739 to $27,378 per instance
  • Category 3 per-day: $8,351 to $27,378 per day
  • Category 3 per-instance: $2,739 to $27,378 per instance

Immediate jeopardy findings must be penalized in the upper range. CMS can impose both per-day and per-instance penalties from the same survey and stack them across multiple citations. A widespread immediate jeopardy finding that takes weeks to resolve can push totals into six figures.

Denial of Payment and Termination

If a facility is still out of compliance three months after the survey that found the problem, CMS or the state must deny payment for all new admissions.13eCFR. 42 CFR 488.417 – Denial of Payment for All New Admissions The same mandatory denial applies to any facility cited for substandard quality of care on its last three consecutive standard surveys. Revenue drops immediately.

Termination of the provider agreement — the contract that lets the facility bill Medicare and Medicaid — is the outer edge. If a facility is not in substantial compliance six months after the last day of the survey, CMS must terminate.14eCFR. 42 CFR 488.412 – Action When There Is No Immediate Jeopardy For immediate jeopardy, that window collapses to as little as 23 days. Termination effectively ends operation as a federal healthcare provider.

Public Disclosure and Star Ratings

Federal regulations require Statements of Deficiencies and approved Plans of Correction to be made public within 14 calendar days after the information is provided to the facility.15eCFR. 42 CFR 488.325 – Disclosure of Results of Surveys and Activities The disclosing agency must also release notices that a facility failed to submit an acceptable plan, notices of termination, and final appeal results. The main public source is CMS Care Compare.

Nursing homes must also post their most recent survey results in a place accessible to residents and families, and keep the last three years of survey reports, certifications, complaint investigations, and any active Plans of Correction available on request.16eCFR. 42 CFR 483.10 – Resident Rights

For nursing homes, CMS-2567 findings drive the health inspection component of the Five-Star Quality Rating System.17Centers for Medicare & Medicaid Services (CMS). Design for Care Compare Nursing Home Five-Star Quality Rating System: Technical Users Guide Each deficiency carries points scaled to its scope-and-severity rating: immediate jeopardy citations carry 50 to 150 points, actual harm citations 20 to 45, more-than-minimal-harm potential 4 to 16, and minimal-harm potential zero. CMS uses a weighted score from the two most recent annual surveys and the previous 36 months of complaint investigations, with the most recent survey counting for three-quarters. Facilities are then ranked against others in the same state. Health inspection is the starting point for the overall Five-Star rating, so it moves the needle more than any other dimension. Abuse-related harm citations cap health inspection at two stars and overall rating at four.

Slow correction compounds the cost. The first revisit adds no penalty points; a second adds half the health inspection score, a third adds 70 percent, and a fourth adds 85 percent. Facilities that need multiple revisits pay for it in their public rating long after the deficiency itself is closed out.