Compliance library · SNF F-tags

F865: QAPI program and plan

Short answer

F865 requires every nursing home to run an effective, comprehensive, data-driven QAPI program and keep the records to prove it. The home presents its QAPI plan at each annual recertification survey and shows proof of use on request. Leaders are accountable. Good faith attempts to find and fix problems cannot be used for sanctions.

F865 · 42 CFR 483.75(a), (b), (f), (h) and (i)CMS
Tag title
QAPI Program/Plan, Disclosure/Good Faith Attempt
Regulation
42 CFR 483.75(a), (b), (f), (h) and (i)
Guidance relied on
Appendix PP Rev. 232 (issued 07-23-25, in use since 04-28-25); F865 section Rev. 211 (02-03-23)
Plan presented
Each annual recertification survey, and on request at other surveys
Survey timing
QAPI review comes last. Surveyors may not use it to find new deficiencies or widen scope or severity
Not protected
Incident and accident reports, wound logs and infection control logs
Refusal to produce evidence
Cited at F865; plan of correction required; remedies up to termination of the provider agreement

Applies to: Medicare-certified skilled nursing facilities · Medicaid-certified nursing facilities · Facilities that are part of a multiunit chain

What F865 covers

F865 enforces the program-level parts of 42 CFR 483.75, paragraphs (a), (b), (f), (h) and (i). These cover the program, its design, governing body accountability, limits on disclosing committee records and good faith protection. The program must be ongoing, comprehensive, data-driven and focused on outcomes of care and quality of life. It must cover all systems of care.

CMS moved the old F866 requirements into F867. Committee membership and meetings are at F868. The home must also keep records and proof of its program, including adverse event systems and corrective action records.

Governing body or executive leadership must keep the program going through staff changes. It must give the program staff time, equipment and training, and check that corrective actions work.

What surveyors check

Surveyors use the Facility Task Pathway for QAPI and QAA Review. They do it after investigating every other area, so their findings stand on their own.

What to have ready
Surveyors ask forHave ready
The QAPI planA written plan based on the facility assessment: how problems are tracked, analyzed and corrected
Proof the program runsRegular data, analysis, and corrective actions with results
Adverse event and problem trackingReports, logs and analysis showing identification, investigation and prevention
Governing body involvementReports to the governing body or its designee, priorities set, resources assigned
Proof of a good faith attemptA dated record of data, analysis, cause, action and monitoring for the issue the survey team found

What QAPI records are protected

Committee minutes and internal papers are generally protected. That ends when they hold the proof needed to decide whether the home meets the QAPI rules. Then the home must let surveyors review and copy them. Incident and accident reports, wound logs and infection control logs are not protected, and surveyors may request them at any point.

If QAPI material is patient safety work product held with a patient safety organization (PSO), surveyors must not ask to see it. They ask to see the PSO agreement. CMS warns of a trap. If all QAPI proof sits in the protected system, the home may be unable to show compliance without a separate non-confidential record.

How to show a good faith attempt

If the committee already found the issue and made a good faith attempt to correct it, the home is not cited for QAPI. Other tags may still apply. Surveyors ask when the home should have known, what it did, and whether enough time has passed to judge the result.

  1. Collect dataFrom incidents, complaints, MDS and audits, on high-risk, high-volume or problem-prone issues.
  2. AnalyzeFind where results fall short of what is expected.
  3. Study the causeFind underlying causes and contributing factors.
  4. ActStart a corrective action with an owner and a date.
  5. MonitorCheck whether the fix holds. Revise it if not.

What raises F865 severity

The F865 guidance has no severity examples. If the home refuses to produce proof of QAPI compliance, surveyors cite F865 and require a plan of correction. Remedies can run up to termination of the provider agreement. QAPI sections are not on the substandard quality of care list in 42 CFR 488.301.

Harm links to other tags. At scope and severity level E or higher, or with substandard quality of care, the QAPI reviewer asks if monitoring should have caught it. Issues likely to cause serious harm, impairment or death must be answered immediately. F867 shows QAPI findings at immediate jeopardy.

Cadence and clocks

ItemTiming
Present the QAPI planEach annual recertification survey; on request at any other survey
QAPI documentation and evidence of implementationOn request of the State Survey Agency, a federal surveyor or CMS
QAA committee meetingAt least quarterly and as needed. See F868
Performance improvement projectAt least annually on a high-risk or problem-prone area. See F867

Gaps that lead to citations

  • The plan is generic, not tailored to this home.
  • Nothing links the plan to the facility assessment.
  • No record shows governing body review of QAPI results or priorities.
  • Minutes list topics with no data, decisions, owners or dates.
  • All QAPI proof sits in a protected PSO system, with no separate record.
  • A good faith attempt is claimed, but no dated actions exist.

How IncidentKit supports F865

IncidentKit keeps the non-confidential record surveyors can ask for: incidents, investigations, corrective actions and an audit trail of who did what and when. Compliance packets assemble QAPI summaries and analytics support setting priorities from data. It does not write your QAPI plan or replace your governing body's review. See the QAPI guide.

How IncidentKit supports this requirement

What the rule asks forWhere it lives in IncidentKit
Documentation and evidence of an ongoing QAPI programIncidents, investigations and corrective actions form a record with an audit trail, and compliance packets assemble QAPI summaries.
Systems that identify, report, investigate, analyze and prevent adverse eventsIntake, routing, investigations and analytics cover the identify-to-analyze steps.
Corrective actions evaluated for effectivenessCorrective actions carry an owner, due date, evidence and effectiveness check. Nothing closes until verified.
Evidence of a good faith attemptDated records of data, analysis, cause, action and monitoring, from the audit trail and analytics.
QAPI plan and governing body oversightIncidentKit does not write your plan or replace governing body review. Attach both to the compliance packet.

Product parts involved: Incident reporting, Investigations and RCA, Corrective actions (CAPA), Analytics, Compliance packets, Audit trail, Multi-site and roles. Capabilities marked “rolling out” are being released in stages; see the changelog.

Frequently asked questions

What does a surveyor review under F865?

Whether the home keeps proof of an ongoing QAPI program, can present its plan, and has governing body oversight. They check at the end of the survey.

Are incident reports protected from surveyors?

No. CMS says incident and accident reports, wound logs and infection control logs are not protected, and surveyors may request them at any time.

Can a nursing home put all QAPI records in a patient safety organization?

Yes, but CMS warns that keeping every QAPI record there may leave the home unable to show compliance. A second, non-confidential system is allowed.

What counts as a good faith attempt?

Proof that the QAA committee found the issue and acted: data, analysis, causes, corrective action and monitoring. A claim alone is not enough.

What happens if a home will not provide QAPI proof?

It is cited at F865 and needs a plan of correction. Remedies can go up to termination of the provider agreement under 42 CFR 489.53.

Sources

Reviewed against the sources above on Oct 5, 2026. Rules change: confirm current requirements with the issuing body or your counsel before relying on any summary.

Start free

Map this requirement to your records.

IncidentKit connects each rule to the incident, investigation and corrective action that satisfy it.