The Lead September 18, 2025 - LeadingAge Illinois

From the Desk of Angela Schnepf, President and CEO

Nursing and Rehabilitation

Illinois Nursing Home Survey Trends
CMS Revises QSO Memos on Care Compare Updates
Regulatory Rule Review – Assurance of Financial Security

Housing
LeadingAge RAD for PRAC Webinar Series: Preserving Your Aging HUD Property

Other
Ask the Expert
Become a 2025 LeadingAge Illinois PAC Partner

From the Desk of Angela Schnepf, President and CEO
CMS Launches Landmark $50 Billion Rural Health Transformation Program

CMS released the applications for the Rural transformation funding. Letters of intent are due September 30. Full applications are due November 5. See the FAQs

This is $50 billion over 5 years so $10 billion a year.

Half is distributed equally among all APPROVED states. This is a grant so each states application will get scored. It is a possible for a state not to get money even if they submit an application if it does measure up.
The other half, “We will distribute the other $25 billion based on the content and quality of your application and rural factors”

Kindest Regards,

Angela

McLean County Nursing Home Hosts Legislative Visit

Tim Wiley, Administrator at McLean County Nursing Home, and residents and staff hosted State Representative Sharon Chung last week. Jason Speaks represented LeadingAge Illinois during the visit. The visit included a meeting with the home’s leadership and a tour. It was the second visit for the representative in the Partners in Quality Campaign in 2025 as she also recently visited Westminster Village. The visits were another stop towards educating a key legislator on aging services. This recent visit also allowed us to focus on the importance of county nursing homes.

IDFPR Online Resources for Nurses

The Illinois Department of Financial and Professional Resources (IDFPR) shared online resources they have available including:

License Regulations – Internationally Educated Nurses English including items required to apply for an Illinois nurse license including if the original licensure required a Credential Evaluation Service and when English equivalency tests are required.
Illinois Nurse License Application Checklist Video which includes information on application by endorsement for those licensed in other states.
Licensed Professionals Applying to Reinstate or Restore an Illinois Professional License
Illinois Nursing Workforce Center website.

CMS Releases the Mission & Priorities Document (MPD) for FY2026

On September 12, the Centers for Medicare & Medicaid Services (CMS) released the Fiscal Year Mission & Priorities Document (MPD) or Admin Info 25-11-All. The MPD outlines CMS’ Priorities by provider type throughout the document. You’ll find an overview by provider type below. The Fiscal Year (FY) 2026 begins October 1, 2025.

Hospice:

CMS notes that they will continue implementation of the Consolidated Appropriations 2021 (CAA) which established new hospice program survey and enforcement requirements, along with expanded requirements for Accrediting Organizations with deeming authority for hospice programs. These requirements were codified in the Calendar Year 2022 Home Health Prospective Payment Rate Update Final Rule. Additionally, CMS notes the temporary pause on the implementation of a Special Focus Program (SFP) which was included in the Calendar Year 2024 Home Health Prospective Payment System Rate Update.

Long-Term Care:

CMS is continuing to test a risk-based survey approach which allows for nursing homes that consistently demonstrate higher-quality performance to receive a more focused survey, improving efficiency and resource utilization compared to standard recertification. Once the testing phase is complete, CMS will announce the ongoing efforts for the risk-based survey process.

Surveyor Training and Education:

CMS is implementing a Surveyor Skills Review (SSR) Assessment annually which will measure the competency and knowledge required for successful surveys. Surveyors will take the SSR assessment after completing all the prerequisite and basic training courses for their primary area of expertise and one year of experience surveying health care facilities. Each surveyor will be notified when they are eligible to take the SSR between October 1 and September 30^th annually. You can view the SSR competency assessments by provider type on the Quality, Safety, & Education Portal (QSEP).

The memo also outlines state survey performance criteria including conducting recertification visits timely and uploading the information to CMS. You can access the most recent State Performance Standards System (SPSS) rating here.

Skin Substitutes in Part B Raise Red Flag for OIG

A new Office of Inspector General (OIG) data snapshot reviews rising Medicare Part B expenditures for skin substitutes over the last two years, which surpassed $10 billion annually at the end of 2024. Skin substitutes are a wound care product that is a material used to cover and promote healing of wounds by acting as a temporary or permanent replacement for damaged skin. Examples of skin substitutes include but are not limited to:

Apligraf
Dermagraft
Biovance
PriMatrix

The OIG analyzed Part B claims data, Medicare Advantage claims data, and manufacturer-reported sales data for skin substitutes in 2023 and 2024 to develop the data snapshot. The analysis by the OIG raised four key concerns:

Large increases in the amount of product billed for each enrollee
A massive gap in spending between Part B and Medicare Advantage
Providers’ propensity to shift to more-and-more expensive products
Potential fraudulent schemes uncovered by OIG

As part of the analysis, OIG found that in the third quarter of 2024, 28% of enrollees with a paid skin substitute claim under Part B were reportedly being treated in their home and accounted for more than half of Part B spending for skin substitutes. However, the data did not indicate if these enrollees were being treated by home health agencies or hospices but includes a Department of Justice (DOJ) case in which a provider targeted hospice patients with inappropriate use of skin substitutes.

As part of the Centers for Medicare and Medicaid Services (CMS) effort to curb waste, fraud, and abuse in the Medicare system, it recently introduced a prior authorization model for Part B Medicare fee-for-service (FFS) through a new Center for Medicare and Medicaid Innovation (CMMI) model called WISeR, or Wasteful and Inappropriate Services Reduction. Additionally, CMS has implemented a Local Coverage Determination (LCD) with an effective date of 10.1.2025 which outlines when skin substitutes are appropriate for use in Medicare beneficiaries and when they are not. If you are currently using a skin substitute on residents/patients in your care, please review the appropriate use LCD to ensure your Medicare claim will be paid.

CDC Viral Respiratory Pathogens Toolkit

As we begin the viral respiratory pathogen season, please review your infection prevention and control resources. The CDC has a Viral Respiratory Pathogens Toolkit that includes overall best practices and links to specific viral respiratory pathogens information (such as COVID-19). As an FYI, the COVID-19 guidance for nursing homes has not been revised (which includes 10 days of isolation following a positive test for residents and at least 7 days of isolation for a staff member following a positive test). LeadingAge National continues to advocate for much needed revised guidance, but with the termination of the recently appointed CDC Director, we are not sure how the advocacy efforts will move forward. LeadingAge Iowa reached out to LeadingAge to inquire about advocacy efforts to ensure that this critical need is followed up on.

Nursing Home Administrators Class for Infection Prevention and Control

Hektoen and the Illinois Department of Public Health (IDPH) having myself, Karen Trimberger have put together a two-day class for Nursing Home Administrators focused on the importance of Infection Preventionists and Infection Prevention and Control programs. They are tentatively planned for January 12-13, 2026 in Northern Illinois and May 18-19, 2026 in Central/Southern Illinois. Cost will be minimal For more information, contact Deb Patterson Burdsall.

LeadingAge Illinois Issues Comments on HFS PBJ Appeals Process

LeadingAge Illinois recently provided comments to the proposed rules for the appeals process for missing Payroll Benefits Journal (PBJ) data for skilled nursing facilities. Click here to read our comment letter.

Upcoming IDPH Training

September 25 from 1 – 2 p.m. 2025/2026 Respiratory Updates

October 24 from 1 – 2 p.m. Monitoring Environmental Cleaning with Fluorescent Marking. This webinar will be open to infection preventionists from all care settings.

IDPH Office of Preparedness and Response (OPR) in conjunction with Texas A&M Engineering Extension Service is hosting Cybersecurity Risk Awareness for Officials and Senior Management on November 4, 2025, from 8 a.m. – 12 p.m. at the IDPH Training Room/PHEOC in Springfield. You can learn more or register here.

The IDPH OPR, in conjunction with Texas A&M Engineering Extension Service is hosting a Cybersecurity Vulnerability Assessment on November 5 & 6 from 8 a.m. – 5 p.m. at the IDPH Training Room/PHEOC in Springfield. This training is designed to address specific technical and professional skills necessary to assess, document, remediate, and report on cybersecurity vulnerability assessments within organizations through a series of lectures and hands on activities. You can learn more and register here.

The Illinois Weather and Public Health Response Summit 2025 is scheduled for November 12 – 13, 2025, at the Student Center West, University of Illinois Chicago. This summit focuses on addressing the health impacts of adverse weather events and strategies for preparedness and response. You can learn more and register here.

November 14 from 1 – 2 p.m. Infection Prevention and Control Aspects of Wound Care

IDPH Revises HCP Return to Work Guidance

On September 17, 2025, the Illinois Department of Public Health issued a SIREN notifying health care providers of updated health care personnel (HCP) work exclusion for acute respiratory illnesses (ARI). The guidance entitled Interim Work Exclusion Guidance for Health Care Personnel with COVID-19, Influenza, and Other Acute Respiratory Viral Infections outlines the following return to work guidance for HCP with symptoms or diagnosed with an ARI based on guidance drafted by the Healthcare Infection Control Practices Advisory Committee (HICPAC).

HCP with mild to moderate ARI who are not moderately to severely immunocompromised, regardless of diagnostic testing performed, should not return to work until at least 3 days have passed since symptom onset, at least 24 hours have passed with no fever (without the use of fever-reducing medicines), symptoms are improving, and they feel well enough to return to work.
- If a positive test result is noted, but the HCP is asymptomatic throughout the infection, they should not return to work until at least 3 days have passed since their first positive test.
- Symptom onset or positive test is day 0, making the first return to work day 4.
Upon return to work, the HCP shall wear a facemask in all areas of the building, including patient care and common areas for at least 7 days after symptom onset or the positive test (if asymptomatic), if not already wearing a facemask as source control.
Consider reassigning or excluding these HCP from care of patients at highest risk of severe disease, including those with moderate or severe immunocompromising conditions, for 7-10 days after symptom onset or resolution, whichever is longer.
HCP who are moderately to severely immunocompromised or who have severe ARI should refer to the individual provider’s occupational medicine, infection prevention, or policy before returning to work as these individuals may shed virus for longer periods. You may consider consulting with infection disease specialists or other experts and/or using a test-based strategy in making this determination.
HCP exposed to influenza, COVID-19, or other ARI and are asymptomatic should wear source control from the day of first exposure through the 5^th day after last exposure, monitor for development of signs and symptoms for 5 days after their last exposure. Work restrictions are generally not necessary and you can reference the CDC’s Interim Guidance for Managing Healthcare Personnel with SARS-CoV-2 Infection or Exposure to SARS-CoV-2 for higher risk exposures.

LeadingAge Illinois staff are reaching out to IDPH representatives to ask if guidance on resident isolation will also be revised. There has not been updates released at this time for residents.

Help Set the 2026 LeadingAge Illinois Legislative Priorities

The last three legislative sessions have been the most successful in association history. We have held off burdensome legislation while also passing important measures from our member-driven legislative agenda.

It is now time to plan for the 2026 session of the Illinois General Assembly, which begins in January. Help us set our 2026 agenda by taking part in one or more of the below forums. Come with any ideas or feedback on challenges you are facing. Our goal is developing solutions to those challenges.

We are making it simple. To register, simply email Jason Speaks at jspeaks@leadingageil.org with the RSVP for the forum date you would like to attend. You will then receive a calendar invitation for the virtual meeting. (Example: Subject: RSVP September 9 Assisted Living Forum).

Legislative Priorities Member Forums:

Nursing Homes

September 23

10:00 – 11:30 am

Housing

October 7

10:00 – 11:30 am

Home and Community Based Services

October 21

10:00 – 11:30 am

Send us your MCO Issues

LeadingAge Illinois is working with the Illinois Department of Healthcare and Family Services (HFS) and the MCOs to resolve MCO billing issues. If you have a pattern of claims issues (not single claims) that you have not been able to resolve using the normal channels, such as working with your provider relations representative or through the use of the complaint portal, we can help by raising attention to these issues.

If you have issues, please contact Jason Speaks.

Illinois Nursing Home Survey Trends

According to the Centers for Medicare & Medicaid Services (CMS) Quality, Certification, & Oversight reports page, the top five deficiencies are consistent with previous reports. Some of these regulations have multiple components to them that are important to review your processes to ensure they are compliant.

F689, Accidents, Hazards, Supervision, and Devices continues to be the most cited deficiency for the calendar year (CY 2025). This has been cited 351 times in 2025. In August, we covered resident smoking requirements and in June, Falls and Elopements. This regulation has many required components that are routinely cited. In this article we’ll cover transfer assistance for residents.

Resident’s transfer assistance requirements may be based on a couple different factors including therapy recommendations (such as physical therapy) or nurse assessment and intervention. It is important that each resident’s recommended transfer status is included in their care plan and that the care plan interventions are communicated to the staff. For example, if a resident is identified as assistance of one staff member, but due to a change in condition, they now require two assistance from staff members, the staff must be able to quickly identify this and use the appropriate assistance to ensure the resident and their own safety. There are likely times when a resident’s condition changes and the charge nurse must make decisions based on their assessment of how to transfer the resident. For example, in the above example, the change of condition may occur at 8 p.m. on a Saturday, in which you will receive assistance from therapy staff until the following week at the earliest. Based on the nurse’s assessment, they determine that it is the safest to transfer the resident with assistance of two staff members until therapy can evaluate the resident. My recommendation is to allow nursing staff to increase the amount of assistance with transfers without first consulting with therapy, but never decrease the amount of assistance without first consulting therapy.

Mechanical lifts also provide relief to physical burdens associated with lifting residents but can present with their own hazards. Here are some considerations with mechanical lifts:

The type of lift used. Residents who cannot bear weight must not use a stand-assist lift.
Specific manufacturer’s recommendations including the types of slings that are compatible with the lift, safety supports such as leg wrap or sling placement, preventative maintenance schedules, etc.
Slings likely come in various sizes and have specific recommendations based on the resident’s weight. Using slings that are too small or large may result in the resident falling out of the sling or the sling being unable to support the resident’s body size.
Batteries that are compatible and charging schedules. When batteries are not functioning properly the lift may not work in the middle of transferring a resident and leave the resident in a vulnerable position.
Locking/unlocking brakes and spreading the legs during appropriate times. Ensuring that the staff use the lift appropriately during the transfer, including when to lock the brakes on the wheels and ensure that the legs of the lift are widened is crucial to ensuring the lift remains upright and the transfer goes smoothly.
Ensuring that the sling is placed correctly during transfers and hooked up appropriately. Slings that have multiple loops may recommend attaching multiple loops in case one fails during the transfer. Additionally, slings may need to have areas crisscrossed to prevent residents from sliding out.
The correct number of staff assistance to use during the transfer. Some lifts may allow one staff member to properly use the lift, while others require two assistance. This is critical to ensure safe and proper technique during the transfer.

Whether residents are independently transferring, require staff assistance, or use a mechanical lift, it is crucial to ensure that the resident’s care plan reflects the transfer status and appropriate devices to be used during the lift. If a resident requires a two-person lift assistance with a gait belt, and staff transfer a resident by themselves they are risking possible resident neglect charges based on placing the resident in an unsafe position as well as deficiencies against the nursing home. While not every situation will result in neglect, it is important that staff are aware that if they willfully make bad decisions during resident care, their actions place them at risk for neglect which may include criminal charges.

Finally, staff must understand that gait belts must be used for all resident transfers. There are very limited exceptions when a resident may not be appropriate to use a gait belt. Again, willful actions of not using a gait belt during a transfer may result in neglect.

F600 free from abuse and neglect is the second most commonly cited deficiency which has been cited 230 times in 2025. F600 is cited whenever the nursing home fails to prevent abuse and neglect by the staff or other residents.

F684 quality of care, is the third most commonly cited deficiency, cited 216 times in 2025. F684 is cited for a variety of reasons, but frequently is cited for the staff failure to identify a change or complete an assessment and intervene when it is appropriate. In previous articles linked above I’ve reviewed identifying a change in condition. Other situations that you may pay close attention to are when your specific policies outline certain expectations of the staff related to assessment and intervention. For example, some providers may incorporate neurological assessments after each unwitnessed fall. While neurological assessments are not required by regulation for every fall, the individual policy would require them, hence the deficient practice. Similarly, if the fall report indicates the resident hit their head, standard of practice would direct staff to complete neurological assessments and if they are not completed it would result in a deficiency.

F880 infection prevention and control is the fourth most cited deficiency and has been cited 215 times in 2025. In previous articles, we’ve explored hand hygiene, enhanced barrier precautions, and glove use. Another example of a deficient practice is staff not placing a barrier down when they are setting equipment down in the resident’s environment. As an example, when a nurse enters the resident’s room to complete a dressing change, they should place a barrier down before placing the dressing change supplies on the resident’s bed or table as you’re unaware of what type of bacteria or contaminates are on the area where you’re placing the supplies. Additionally, placing a barrier on the floor before placing a graduated cylinder down to empty a catheter drainage bag is a common example cited under this regulation or under F690.

Finally, the fifth most cited deficiency is F686, treatment and services to prevent/heal pressure ulcers. LeadingAge Illinois has completed several resources recently on pressure ulcers including:

Pressure Ulcer Quality Assurance Guidance
Pressure Ulcer Quality Assurance Worksheet
Clinical Best Practice articles on Repositioning, Nutritional Considerations, and Positioning Support Devices to prevent pressure ulcers.
Quality Measure webcast including strategies to reduce quality measure percentages.

CMS Revises QSO Memos on Care Compare Updates

On September 10, 2025, the Centers for Medicare & Medicaid Services (CMS) revised the Quality Safety and Oversight regarding Updates to Nursing Home Care Compare (QSO-25-20-NH Revised). The revisions in the memo further delay new processes for antipsychotic medication use on Nursing Home Care Compare. CMS notes that the current national percentage of residents receiving an antipsychotic is 14.64% which is projected to increase based on additional data that will be included and will result in improved accuracy.

Additionally, CMS revised the Quality & Safety Special Alert Memo (QSSAM) 25-03-NH Revised on Temporary Pause in Nursing Home Care Compare Updates. The revised letter indicates that CMS will update the Nursing Home Care Compare website to reflect changes based on findings from payroll-based journal and schizophrenia coding audits as well as nursing homes’ Special Focus Facility (SFF) status, beginning with the September 24, 2025 refresh with all other information, including the health inspection status will continue to be based on July 30, 2025 data. CMS anticipates a regular refresh in October 2025. As a reminder, CMS paused the updates to validate data integrity of the completed nursing home surveys based on transition from ASPEN to iQIES.

Regulatory Rule Review – Assurance of Financial Security

The last regulation in the residents’ rights section pertaining to resident trust funds includes F570. In this regulation, the Centers for Medicare and Medicaid Services (CMS) requires nursing homes who have a resident trust fund to provide financial security for those funds in the event someone misappropriates those funds. Compliance with this requirement is generally in the form of a surety bond, but can also be other methods as long as the nursing home is able to provide documentation of financial security. The amount of the surety bond must be at least the amount of funds that are deposited within the resident trust fund. For example, if you have a balance of $9,000 total, the surety bond would not be compliant if the value was only $5,000.

The interpretive guidance provides a couple key compliance tips:

The nursing home cannot self-insure the funds.
Funds deposited in a bank account that is protected by the Federal Deposit Insurance Corporation (FDIC) does not fulfill the financial security requirement.
The nursing home cannot be listed as the beneficiary – it must be the residents or the state.
If a multi-site provider has one policy, there must be separate declaration pages for each location that accepts resident funds.
Refundable deposit fees must be included in the financial assurance compliance.

During survey, the surveyors will generally ask providers to show documentation of the surety bond which can be fulfilled by providing a copy of the declaration page from your bond. This regulation is rarely cited, but instances of deficiency generally related to the value of the surety bond not being adequate to cover the entirety of deposited funds.

LeadingAge RAD for PRAC Webinar Series: Preserving Your Aging HUD Property

Join LeadingAge for a special mini-series on the Rental Assistance Demonstration (RAD), a critical senior housing preservation tool administered by the Department of Housing and Urban Development (HUD). Many affordable senior housing providers are exploring preservation options for aging PRAC properties with limited opportunities to attract recapitalization and rehabilitation investment; the September webinar series, taught by affordable housing expert Gates Kellett, reviews the basics of RAD and then dives into best practices and pitfalls to avoid. Whether you are just beginning to explore RAD or seeking to refine your approach, this insightful two-part webinar will provide valuable knowledge and practical guidance for making informed decisions and ensuring the long-term success of your housing portfolio.

Ask the Expert
A number of member questions come in daily to the association. In this article we will feature unique or recent questions of interest to members.

Q: The nursing home surveyor told me that I would not receive a CMS-2567B once I passed my revisit. Is this accurate and how will I know I am in substantial compliance?

A: According to IDPH this is accurate. Nursing homes will be able to identify that they are back in substantial compliance once they receive an “F” notice. Additionally, when you view the survey F-tags in iQIES it will indicate the deficiency was corrected.

Have a question? Email yours now.

Become a 2025 LeadingAge Illinois PAC Partner

We must continue to leverage our PAC to educate legislators, to reduce burdens, and implement solutions that impact YOU.

Each contribution, no matter how small, makes a difference. Like our voices, our contributions collectively make a significant difference in providing the ability to influence public policy related to aging services.

Last year, the PAC was instrumental in helping move forward our public policy priorities to unanimous passage in the Illinois General Assembly.

Become a PAC Partner and help us advance our public policy priorities and defeat harmful and burdensome legislation that would have a negative impact on member communities.

There are a number of ways to engage in the LeadingAge Illinois PAC.

Monthly Contribution (most popular). You can contribute smaller amounts each month, spreading your total contribution over the year. Select “make this a monthly donation” when processing your payment.
Make a one-time contribution– Visit our webpage online to make a one-time contribution.
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*Nonprofit 501c(3) organizations cannot by law fund the PAC with a corporate check. Donations must come from individual contributions. We recommend sharing this communication with your staff to encourage personal contributions.

**Contributions to PAC are not deductible as charitable contributions for tax purposes.

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