Reading a CMS Form 2567: F-Tags and Scope-Severity Letters

Somewhere on page 2 of a six-page complaint survey report, the columns stop being a form and start being a story:

F 0689 SS=D Bldg. 00

483.25(d)(1)(2) Free of Accident Hazards/Supervision/Devices

Based on record review and interview, the facility failed to supervise a resident, with severe cognitive deficits and wandering behaviors, from exiting the facility resulting in the elopement of Resident E.

Three fields sit above that sentence, and none of them are written in English. F 0689 is an address. SS=D is two separate judgments compressed into one character. Bldg. 00 is a building code. Everything underneath is narrative, and the narrative is the part families read. The three fields are the part that decides what happens next.

The header boxes, and which date each one is

The form is Form CMS-2567, Statement of Deficiencies and Plan of Correction, OMB control number 0938-0391. The boxes across the top are numbered X1 through X6 and each carries a different piece of identity or timing.

Below the header, before any citation, sits a block tagged F 0000 and titled INITIAL COMMENTS. It is not a deficiency and carries no letter. It is where the surveyor records what kind of visit this was. A real one from an Indiana complaint survey lists four complaint numbers, states which of them produced no related findings, gives the survey dates, the facility number, the provider number, the census by bed type and by payer, and the state licensing rule the findings also cite. Read that block first. It tells you which kind of visit produced the pages in your hand: an annual recertification survey, or an investigation of one specific allegation. Very different documents, identical paper.

At the foot of every page: an Event ID and a Facility ID. Request the same report twice and those are the two numbers that tell you it is the same document.

The F-number is an address, not a score

F-tags do not rank anything. Each one points at a paragraph of 42 CFR Part 483, Subpart B, and the numbers run in the same order as the regulation. The current inventory is a two-page CMS chart, Federal Regulatory Groups for Long Term Care, April 2026 edition: 198 tags, F540 through F949, printed under the regulation section each one enforces.

A few tags cite two sections at once, so the blocks are not perfectly clean. But the shape holds: an F6xx is about rights, abuse, transfers or care planning; an F8xx is usually food, administration or infection control.

The 483.15 row is the one that moved most recently, and it is the row a family fighting a discharge ends up in. Effective 25 April 2025, CMS retired five transfer-and-discharge tags — F622, F623, F624, F625 and F626 — along with the two discharge-planning tags F660 and F661, and folded what all seven covered into two new numbers: F627, Inappropriate Transfer and Discharge, and F628, Discharge Process. Appendix PP now prints a one-line note under each retired number saying where its requirement went. (CMS prints more than one name for F627 — Inappropriate Discharges on the April 2026 tag list, Inappropriate Transfer and Discharge in Appendix PP's cross-references — so two CMS documents disagreeing about the name is not a sign that either has the wrong tag.)

The July 2026 citation file shows the switch happening on schedule. F623 was cited 1,244 times on 2024 surveys and 442 times on 2025 ones, then stops. F627 and F628 have no citations before 2025 at all, and none of the seven retired numbers appears on a 2026 survey; F627 and F628 carry 246 and 771 rows that year, while F620 and F621, which were not retired, carry 14 and 1. So a 2024 report on a discharge reads F623 or F625, and a 2026 report on the same conduct reads F627 or F628. The regulation did not change. The address did.

That is the smaller version of a bigger trap. The whole numbering scheme only exists from 28 November 2017 — the phase-two implementation date of the 2016 requirements of participation rule, when, in CMS's words in memo S&C 17-36-NH, "these new F-Tags will be used after November 28, 2017." Surveys before that date carry an entirely different scheme, and those numbers do not decode against Appendix PP at all. If a facility hands you a binder covering a decade, check the (X3) date before you look up anything in the front half of it.

Twelve cells, two questions

The letter answers severity and scope in one stroke. Severity runs in four bands down the side; scope runs in three columns across. The State Operations Manual defines scope plainly: isolated when one or a very limited number of residents or employees is affected, pattern when more than a very limited number are affected but the locations are not dispersed throughout the facility, widespread when the problem is pervasive or represents a systemic failure.

The share column below is mine, counted from the 418,344 health citations in CMS's July 2026 public file. Points are from Table 1 of the Five-Star Technical Users' Guide, July 2026 edition; the figures in parentheses apply when the citation is substandard quality of care.

The single most useful boundary on that table is the one between F and G. Everything from A to F describes exposure. G and above describes something that reached a resident. Immediate jeopardy, at J, K and L, has a defined meaning at 42 CFR 488.301: noncompliance that "has caused, or is likely to cause, serious injury, harm, impairment, or death to a resident."

Two of those twelve cells behave oddly. A never appears at all: the manual's own matrix marks that cell "Not on CMS-2567," and isolated level-one findings go on a separate document called Form A, the Notice of Isolated Deficiencies Which Cause No Actual Harm With the Potential for Minimal Harm, which requires no plan of correction. I is close to a unicorn. Twenty rows out of 418,344.

So a report full of D and E citations is not a clean report and not a damning one. It is an ordinary one. Eighty-five percent of all health citations in that file were D or E.

The right-hand column is the facility talking

The two columns are not two halves of one voice. The left is the surveyor. The right is the facility, written afterward, and it is the column most families skim.

The regulation and the deadline come from different places. 42 CFR 488.402(d) requires a plan of correction at all; the clock is in the manual, at section 7317 of State Operations Manual Chapter 7, which gives the facility 10 calendar days from the date it receives its CMS-2567. Two kinds of finding are exempt: level A, and anything cited as past noncompliance, which is already fixed by the time it is written up. The manual sets five required elements: how the residents already affected will be corrected; how the facility will identify others with the potential to be affected; what systemic change stops recurrence; how performance will be monitored so the fix holds; and dates for completion, which must be acceptable to the state.

The manual also says what the column legally is: "The plan of correction serves as the facility's allegation of compliance and, without it, CMS and/or the State have no basis on which to verify compliance." An allegation, not an admission. Facilities know this, and many print a standing disclaimer at the top of every entry. From the Indiana report:

By submitting the enclosed materials, we are not admitting the truth or accuracy of any specific findings or allegations. We reserve the right to contest the findings or allegations as part of any proceedings and submit these responses pursuant to our regulatory obligations.

That paragraph is boilerplate and tells you nothing about the facility. What tells you something is the (X5) date beside it, and whether the corrective action underneath it is a specific systemic change or a restatement of the rule that was broken.

Missing plans exist and are recorded. In the July 2026 file, 1,629 citations carry the status "Deficient, Provider has no plan of correction." A further 5,997 are marked past noncompliance, the exempt category above. Under 42 CFR 488.456(b), failure to submit an acceptable plan of correction is grounds for terminating the provider agreement.

Facilities can also formally dispute a citation. Informal dispute resolution under 42 CFR 488.331 is offered on request after the official statement of deficiencies arrives, and a separate independent IDR exists under 488.431 when a civil money penalty is going into escrow. It is rare: 646 citations were flagged under IDR in that file and 159 under independent IDR, together under one in five hundred. A pending dispute does not pull the citation off the page; it only holds the points back until the process ends.

Substandard quality of care is a defined term with teeth

Certain letters, cited against certain regulations, trigger a separate process. Substandard quality of care means a deficiency at immediate jeopardy, or a pattern of or widespread actual harm, or a widespread potential for more than minimal harm with no actual harm, cited against a listed set of requirements. When one is found, 42 CFR 488.325(g) gives the facility 10 working days to hand the state a list of every affected resident and the name and address of each one's attending physician. Under paragraph (h), the state then has 20 calendar days to write to those physicians and to the board that licenses the administrator.

The April 2026 chart behind the table earlier in this piece is also the fastest way to check whether a particular citation crosses that line. Substandard-quality-of-care tags are asterisked on it, with a note naming the qualifying letters: F, H, I, J, K and L.

Which brings up the thing that will trip you before any of the substance does. CMS is currently distributing two different copies of Chapter 7, and they are sixteen years apart.

The copy inside the Survey Resources ZIP on the nursing homes page is Revision 244, issued 26 June 2026. It defines substandard quality of care using the sections that are actually in force — parts of 483.10, all of 483.12, 483.24, 483.25, 483.40(b) and (d), 483.45(d) through (f), 483.70(p) and 483.80(d) — which matches 42 CFR 488.301 word for word. It numbers the plan-of-correction rules 7317, and the severity-and-scope matrix 7203.3.2.

The copy still sitting at the manual's own download URL, the one a search engine hands you, is Revision 63, issued 10 September 2010. It defines substandard quality of care by the pre-2016 section numbers 483.13, 483.15 and 483.25, which no longer describe what they used to. It numbers the same plan-of-correction rules 7304.4. Both files were live on 22 August 2026.

Appendix PP has the same split. The ZIP carries Revision 232 of 23 July 2025, 926 pages, with the retired discharge tags marked. The standalone PDF at the guidance download URL is Revision 225 of 8 August 2024, 873 pages, and still has F622 through F626 as live tags.

CMS's consumer fact sheet on the five-star system is a third example, and the oldest: it still calls the site Nursing Home Compare and describes the health inspection rating as built from the three most recent annual standard inspections, where the July 2026 Technical Users' Guide uses two, weighted three-quarters and one-quarter. None of these documents is marked as superseded. The revision line at the top of the first page is the only thing that tells you, so read it before you quote anything at anyone.

Where the paper actually lives

The facility. 42 CFR 483.10(g)(11)(ii) requires a nursing home to have reports of any surveys, certifications and complaint investigations from the three preceding years, plus any plan of correction in effect, "available for any individual to review upon request," and to post notice that they exist. Any individual. Not just residents, not just family. Paragraph (g)(10) gives the resident the right to examine the most recent survey, and (g)(11)(i) requires the most recent one to be posted where residents and families can reach it.

Care Compare. medicare.gov/care-compare carries the inspection findings and the star ratings built from them.

The provider data catalog. data.cms.gov/provider-data publishes the Health Deficiencies file, one citation per row, refreshed monthly. The July 2026 edition is where the citation counts in this piece come from. Its columns include the CCN, survey date, deficiency tag number and description, scope-severity code, whether it was a standard or complaint deficiency, whether it is under IDR, the correction status and the correction date.

The state survey agency. Several states publish scanned CMS-2567 PDFs directly. CMS keeps a page of contact information for state survey agencies. The state long-term care ombudsman also receives the statement of deficiencies, the facility's written response, and any appeal request, under 488.325(f), and is a person rather than a portal.

Timing changed recently, and the form has not caught up. The blank CMS-2567 still prints the old rule at the foot of its signature page: findings disclosable after 90 days for most providers, 14 days for nursing homes. CMS memo QSO-25-19-All, dated 18 June 2025, dropped the 90-day hold for everyone. The CMS-2567 is now releasable as soon as the provider receives it.

What to hold the report against once you have it

A 2567 read on its own will mislead you in three particular ways, and each one has a second document that corrects it.

The calendar comes first. 42 CFR 488.308 requires a standard survey no later than 15 months after the last day of the previous one, with a statewide average of 12 months or less across a state. So if the newest recertification survey in front of you is 20 months old, either that home's cycle slipped or somebody handed you the wrong copy.

Then the star rating, which does not count everything the report shows you. The health inspection domain uses the two most recent recertification cycles, three years of complaint and focused infection control surveys, and revisit penalties. Findings from the third-oldest cycle sit on the page and score nothing. Two tags, F731 and F884, are excluded from the calculation outright. A citation can be in front of you carrying zero weight in the number printed beside it.

Third, the handful of tags a family tends to end up arguing about. Transfer and discharge live at 483.15, now cited as F627 and F628, and that is the same regulation behind the discharge grounds written into an admission packet; the notice provisions inside it are what a fast appeal of a skilled nursing discharge runs on. Searching a home's reports for those two numbers tells you whether the argument you are dreading has already happened at this address. None of this reaches assisted living, which is licensed state by state with no F-tag scheme and no CMS-2567 behind it. The document that decides a move-out there is not a regulation at all. It is the residency agreement, and it says whatever it was drafted to say.

One D on one report is noise. The same tag at D, then E, then G across three consecutive cycles is a line going the wrong way, and it is only visible if the cycles are laid out together — which is why 483.10(g)(11)(ii) says three years and not one.

Sources

Retrieved 21 August 2026; every CMS document below was re-checked against the live URL on 22 August 2026.

• Blank Form CMS-2567, Statement of Deficiencies and Plan of Correction, OMB No. 0938-0391, including the instructions for completion on the back sheet and the disclosure footnote at the foot of the signature page. The form's OMB approval line reads "Expires 03/31/2025."
• CMS, State Operations Manual Chapter 7, Revision 244, issued 26 June 2026, taken from the Survey Resources ZIP linked from the CMS nursing homes page. Section 7317 (acceptable plan of correction, the five elements, the 10 calendar day rule and the "allegation of compliance" sentence), 7203.3.2 (the seriousness matrix, including the "Not on CMS-2567" note in the A cell), 7410.2.1 (scope definitions), 7319.1 (Form A) and 7001 (the current substandard-quality-of-care definition).
• The older copy of the same chapter, Revision 63 of 10 September 2010, still served at the manual's download URL on 22 August 2026. It numbers the plan-of-correction rules 7304.4 and 7400.5.1 and carries the superseded 483.13 / 483.15 / 483.25 definition. The renumbering came through CMS, QSO-26-03-NH, Revisions to the State Operations Manual Chapters 5 and 7.
• CMS, "Federal Regulatory Groups for Long Term Care," April 2026, filed as List-of-Revised-FTags.pdf in the same Survey Resources ZIP. Two pages, 198 tags, F540 through F949; the F-tag-to-section table above is that chart transcribed. Substandard-quality-of-care tags are asterisked, with a note naming the qualifying letters F, H, I, J, K and L.
• CMS, State Operations Manual Appendix PP. The copy in the Survey Resources ZIP is Revision 232 of 23 July 2025, 926 pages, and carries the notes recording that 483.15(c), (d) and (e) and 483.21(c)(2) were relocated to F627 and F628 effective 25 April 2025. The standalone PDF at the guidance download URL was still Revision 225 of 8 August 2024, 873 pages, when checked on 22 August 2026.
• CMS, S&C 17-36-NH, Revision to SOM Appendix PP for Phase 2, F-Tag Revisions, and Related Issues, 30 June 2017, source of the November 28, 2017 changeover and of the old-tag-to-new-tag crosswalk.
• 42 CFR 488.301 (immediate jeopardy, substandard quality of care, substantial compliance), 488.308 (survey frequency), 488.325 (disclosure, ombudsman, physician notification), 488.331 (informal dispute resolution) and 483.10(g)(10) and (g)(11) (posting and review rights), retrieved through the eCFR versioner API, title 42 issue date 13 August 2026.
• CMS, QSO-25-19-All, Release of CMS-2567: Statement of Deficiencies and Plan of Correction, 18 June 2025.
• CMS, Design for Care Compare Nursing Home Five-Star Quality Rating System: Technical Users' Guide, July 2026 edition, Table 1 and the health inspection scoring rules, including the F731 and F884 exclusions and the treatment of the third-oldest cycle.
• CMS, Five-Star Quality Rating System consumer fact sheet, four pages, carrying no revision date and mentioning nothing later than 2015, still live on 22 August 2026 and still describing the three-survey health inspection method.
• CMS provider data catalog, Health Deficiencies, file NH_HealthCitations_Jul2026.csv, released 29 July 2026. All distribution figures here are my own counts from that file: 418,344 citations across 14,629 facilities, survey dates from 23 March 2017 to 22 June 2026, with 85 percent dated 2023 or later. The scope-severity shares, the plan-of-correction status counts, the IDR counts and the tag-by-year counts for F620 through F628 are all tabulated from the same rows. Percentages are of all rows, not of facilities.
• The quoted F 0689 entry and the plan-of-correction disclaimer come from a published Indiana complaint survey report, event ID D6D811, survey completed 31 March 2023, cited at D and corrected. It appears here as a specimen of the form's layout, and a 2023 citation now falls outside the three-year window used for ratings.

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