CMS is changing how it identifies nursing homes for the Special Focus Facility (SFF) program, and the shift is notable: overall fall prevalence is now a central signal of risk, rather than staffing levels serving as the primary indicator. 

The updated approach reflects CMS's view that staffing data alone does not fully explain resident outcomes. Facilities with similar staffing profiles can experience very different fall patterns—prompting regulators to place greater emphasis on what is actually happening to residents over time. 

What's Changed 

Under the revised criteria, CMS is placing more weight on: 

• Fall prevalence and repeat patterns 
• Trends drawn from MDS quality measures 
• Survey findings and complaint histories that indicate sustained safety concerns 

Staffing data remains part of the picture, but CMS has made clear it is no longer the dominant driver in SFF selection. 

Why CMS Is Making This Shift 

Falls are one of the most common and visible indicators of resident safety. CMS has indicated that fall patterns offer a clearer, more direct window into daily operations than staffing metrics alone—capturing how care planning, supervision, and the environment function together. 

This aligns with a broader regulatory direction: outcomes matter more than proxies. 

What This Means for Operators 

For providers, the implication is straightforward but significant: 

• Improving staffing metrics alone may not reduce regulatory risk 
• Persistent fall rates can elevate scrutiny even in otherwise stable operations 
• Demonstrating sustained reduction in falls is becoming increasingly important 

Fall prevention and management are no longer just clinical priorities—they are becoming regulatory differentiators. 

The Role of the Built Environment 

While CMS does not prescribe specific solutions, its emphasis on fall prevalence highlights the importance of looking beyond staffing and protocols alone. The physical environment plays a meaningful role in how residents move, balance, and recover from falls. 

Design and flooring strategies that support safer movement and reduce the impact of falls can complement care-based interventions—especially as regulators focus on patterns rather than isolated events. 

Reading the Signal 

CMS's updated SFF criteria reinforce a simple reality: fall outcomes are now a clearer measure of quality than staffing inputs alone. Operators that address fall risk holistically—across care practices and the built environment—will be better positioned as oversight increasingly follows the data. 

Sources:
Centers for Medicare & Medicaid Services (CMS)
Minimum Data Set (MDS) Quality Measures