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CMS Overhauls CMP Reinvestment Program to Support Nursing Home Innovation

(Sept. 30, 2025) On Sept. 29, 2025, the Centers for Medicare and Medicaid Services (CMS) released memo QSO-25-26-NH, announcing significant updates to the Civil Money Penalty Reinvestment Program (CMPRP). These changes reflect successful advocacy efforts by LeadingAge National and its affiliates, aimed at expanding funding opportunities and improving care in nursing homes. A key change is the centralization of the application review process at CMS headquarters in Baltimore, streamlining intake, final reviews, and decision letters. Emergency fund utilization will still be coordinated regionally.

CMS has also introduced a standardized application form, now required for all submissions 45 days post-memo release, eliminating extension categories and requiring prior project results for expansions. If you have already submitted an application to the CMS CMPRP Team and have not yet received a decision letter (approval, denial, or withdrawal recommendation) or other feedback, you do not need to resubmit your proposed project using the new Application Form.

Under 42 Code of Federal Regulations (CFR) § 488.433(e)(1), State Agencies (SAs) must continue to review applications for alignment with CMPRP goals and forward approved submissions to CMS at CMP-info@cms.hhs.gov. SAs will no longer be required to submit a letter of attestation for previously approved CMP-funded projects seeking expansion into a different set of nursing homes, as CMS will accept the state’s referral as a recommendation for the project’s approval. This also applies to new project applications.

To support broader participation and account for inflation, CMS has raised the funding cap from $5,000 to $6,000 per project, applicable to resident/family councils, consumer information, training, and quality-of-life initiatives. Facilities may now participate in up to three separate training projects over three years, totaling $18,000, with higher requests considered if justified. Applicants must clearly demonstrate the necessity and reasonableness of all requested funds in their application and throughout the project duration. CMS will not automatically approve the maximum amount allowable for a project. CMS will consider requests that exceed established funding caps if a strong justification is provided. Exceptions may be granted at CMS’s discretion on a case-by-case basis, particularly when a proposed project's potential to enhance resident care and quality of life is significant and evident.

Importantly, CMS has reinstated technology funding, recognizing its role in enhancing resident-centered care. These efforts build on resources from the CMS Nursing Home Resource Center. CMS has expanded the allowable technology lists to align with program goals.

CMS is now accepting applications for behavioral health projects, including mental health support and training. This is due to the ending of a temporary pause implemented during the Center of Excellence for Behavioral Health in Nursing Facilities initiative to avoid duplicative funding. In September 2022, CMS partnered with the Substance Abuse and Mental Health Services Administration to launch a three-year national Center of Excellence. This initiative provided technical assistance and training to nursing homes nationwide to strengthen the delivery of high-quality, effective care for residents with behavioral health needs. Following the conclusion of this initiative in September 2025, all training materials and resources will remain available to nursing homes through the Nursing Home Resource Center at CMS.gov. CMS encourages facilities to continue utilizing these tools for staff development and enhanced behavioral health care delivery.

In alignment with the Nursing Home Staffing Campaign, CMS is funding workforce enhancement projects that improve staff competency, support culture change, and reduce burnout – targeting Registered Nurses (RNs), Certified Nursing Assistants (CNAs), and Licensed Practical Nurses (LPNs). The campaign is a targeted workforce enhancement initiative focused on increasing the number of nurses working in nursing homes through financial incentives and training opportunities.

To ensure accountability, CMS now requires demonstrated success before projects can be replicated in other states, along with streamlined reporting timelines and public posting of CMP fund balances and state plans to enhance transparency.

The updated reporting parameters to support more measurable outcomes and streamline reporting requirements include the following guidelines. Applicants must submit results to the SA for review, following the reporting schedule outlined below:

  • Multi-year projects (two or three years): Reporting is required at 12- and 24-month intervals following the project initiation. If an applicant submits a new application to expand a currently funded project, results must also be submitted by the ninth month of the final project year.
  • Single-year projects: One-time reporting required at the end of the project. If an applicant submits a new application to expand a currently funded project, results must be submitted by the ninth month of the project year.

Updated resources will be available starting Oct. 6, 2025, with program revisions effective Oct. 9, 2025. For more information, visit the CMS CMPRP Updates page or LeadingAge National’s summary.

Contact: Carrie Mosley, cmosley@leadingageny.org, 518-867-8383 ext. 147