In late January, CMS revised the Special Focus Facility program.
In late January, CMS revised the Special Focus Facility program. A few days later, another QSO was released that drew significant attention, and this update did not receive the same level of discussion.
One change, however, deserves a closer look.
CMS has advised State Survey Agencies to consider the prevalence of falls when selecting facilities from the SFF candidate list, particularly when facilities have similar compliance histories. While staffing data remain part of the evaluation, falls prevalence is now explicitly part of the selection focus.
At first glance, this may seem relevant only to facilities that are on or near the SFF candidate list. It is not.
A Broader Regulatory Direction
The revised QSO references the Office of Inspector General’s report highlighting the seriousness of resident falls and concerns about underreporting. That context is important.
Falls are already visible across multiple oversight mechanisms:
- Falls are measured and publicly reported through SNF QRP Quality Measures.
- Claims-based data are increasingly used to validate reported outcomes.
- Repeat fall-related deficiencies remain common survey findings.
- Public reporting makes fall performance more transparent than ever.
When CMS explicitly incorporates falls prevalence into the SFF selection process, it reflects a clear policy priority. The SFF program targets facilities with persistent compliance challenges, so the metrics emphasized there provide insight into what CMS views as high-risk areas.
Even though this change applies directly to SFF selection, it underscores the continued attention on fall outcomes and prevention systems.
What This Means in Practice
Facilities that are currently on or near the SFF candidate list should certainly be evaluating their fall trends and systems. However, even organizations with strong compliance histories should take note.
Increased emphasis on falls suggests:
- Closer scrutiny of accident prevention systems.
- Greater reliance on comparative data.
- Increased attention to repeat deficiencies.
- Heightened expectations for sustained improvement.
This is less about one program and more about sustained operational performance.
Experience From the Field
Polaris recently served as the external quality improvement consultant for a Special Focus Facility that graduated from the program in nine months.
The work was not limited to preparing for surveys. It involved rebuilding operational processes, strengthening leadership accountability, and addressing repeat deficiencies at their root. That included reviewing accident prevention systems and ensuring that fall-related trends were being analyzed and addressed in a meaningful way.
Graduation required sustained performance, not short-term fixes.
The Takeaway
The revised SFF guidance may appear narrow, but the emphasis on falls is deliberate. It reflects continued attention to measurable resident safety outcomes supported by data and reinforced through enforcement.
Whether your facility is on the SFF candidate list, monitoring its compliance trajectory, or focused more broadly on quality improvement, fall prevention should be evaluated through a systems lens.
For nearly 40 years, Polaris Group has worked alongside nursing homes to address complex compliance challenges and strengthen operational performance. Whether supporting facilities through the SFF process, improving fall prevention systems, or stabilizing broader quality initiatives, our focus remains the same: building systems that produce sustained results.

