CMS Posts Update to Nursing Home Critical Element Pathways

CMS; Survey and Certification
 

On February 4, 2026, the Centers for Medicare and Medicaid Services (CMS) posted an updated Survey Resource folder, which included updates to several Critical Element Pathways (CEPs). 

Most of the changes are typographical in nature, but the CEP CMS-20081 Respiratory Care did have several updates noted. These include: 

A clarification was added regarding “No Smoking” signs for oxygen use. Previously, the CEP stated under “Observations”: “Are ‘No Smoking’ Signs present wherever oxygen is stored and/or administered;”.  The updated CEP now differentiates between smoking and non-smoking facilities. The updated CEP states the following regarding “Smoking Signs: 

  • Smoking facilities: Are doors labeled “No Smoking” at all locations where oxygen is stored or used? 

  • Non-smoking facilities: Are “No Smoking” signs posted at all major entrances and on doors to all oxygen storage locations? 

Nursing homes should review their policies and procedures to align with the updated guidance, provide education to staff of the changes to ensure compliance. Questions about the updated CEPs may be directed to regulatory@ahca.org