CMS Special Focus Facility (SFF) Program Overview
Understanding SFF Status
When a nursing home is identified as a Special Focus Facility by CMS it means the facility has serious and persistent quality issues. Investors, lenders, and operators should understand what this means for reputation, financing, and long-term stability.
Why it’s a problem for operators and stakeholders…
-Reputation risk > Being publicly listed erodes trust with lenders, investors, and stakeholders
-Financial risk > May affect access to capital, valuations, and lending terms
-Operational pressure > Facilities face stricter timelines and oversight to correct issues
What it means to be on the SFF list…
-Facilities are selected due to a pattern of serious deficiencies
-CMS places them under heightened survey scrutiny
-Homes remain on the list until they show sustained improvement or are terminated from Medicare/Medicaid
Path to exiting the SFF program (per CMS rules)
1- Achieve two consecutive standard health surveys with 12 or fewer deficiencies each
2- Avoid any “F” or higher scope/severity citations
3- Ensure no intervening complaint or fire/life safety survey violations
4- Maintain improvements after graduation for a multi-year monitoring period
5- Demonstrate good faith efforts — such as improved staffing and quality systems
Ready to see CMS’s graduation criteria in StarPRO?
What happens if a facility does not improve?
Per CMS rules, facilities that fail to improve face:
-Progressive enforcement actions (civil monetary penalties, denial of payments, directed plans of correction)
-Termination from Medicare/Medicaid participation — this is the ultimate penalty, and for most nursing homes it effectively means:
Loss of primary revenue streams (since Medicare/Medicaid fund the majority of residents)
Inability to admit new residents under these programs
Rapid financial collapse or closure, unless the facility finds private-pay alternatives (rare)
-Market consequences > once terminated, facilities may be forced to close, sell, or undergo significant restructuring
-Stakeholder impact > investors and lenders face financial write-downs, and operators lose trust in their market
Failure to graduate from SFF status doesn’t just damage reputation — it can mean the end of Medicare/Medicaid and the eventual closure of the home
How StarPRO helps…
StarPRO provides the full picture behind SFF designations:
Deficiency history and severity trends
Staffing and quality measure performance
Peer and market benchmarking
Stability scoring and improvement tracking
Recommended next steps for SFF facilties
-For operators: Use StarPRO to identify the deficiencies, staffing, and survey factors driving SFF designation and track a roadmap to graduation
-For investors and lenders: Use StarPRO to monitor stability risks and evaluate the likelihood of sustained improvement before making financing decisions