09/04/2025

CMS Clarifies Guidance Following Expired QSO and S&C Memoranda

On September 2, 2025, CMS posted notice regarding several Quality, Safety & Oversight (QSO) and Survey & Certification (S&C) memoranda that have now expired. Some of these memos had already lapsed in prior years, while others expired more recently on April 28, 2025. The key takeaway from this posting is that CMS is providing clarity: providers should not look to expired memos for direction but instead reference current requirements outlined in the State Operations Manual (SOM), Appendix PP, or in newer QSO memos when applicable.

Key Expired Memos and Where to Look Now

• QSO-21-19-NH (COVID-19 Vaccine Requirements): Expired April 28, 2025. Now refer to: QSO-25-11-NH for respiratory illness reporting and F887 in Appendix PP for COVID-19 immunization requirements.
• S&C: 10-28-NH (Point of Care Devices & Infection Control): Expired April 28, 2025. Now refer to: F880 in Appendix PP for infection control standards, including fingerstick devices and blood glucose meters.
• S&C: 14-25-NH (Single Use Device Reprocessing under F441): Expired April 28, 2025. Now refer to: F880 in Appendix PP for infection control requirements regarding single-use devices.
• S&C: 17-30-Hospitals/CAHs/NHs (Legionella Risk Reduction): Superseded July 16, 2018. Now refer to: Revised QSO-17-30 for updated requirements regarding Legionnaires’ Disease prevention.
• S&C: 12-22-NH (HAI Prevention Environmental Scan): Expired December 31, 2012. Note: This was a time-limited environmental scan and is no longer in effect.
• QSO-24-08-NH (Enhanced Barrier Precautions for MDROs): Expired April 28, 2025. Now refer to: F880 in Appendix PP for current guidance on enhanced barrier precautions.
• S&C: 13-09-NH (Laundry and Infection Control under F441): Expired April 28, 2025. Now refer to: F880 in Appendix PP for infection control requirements related to laundry and water management.