How to read an ICF inspection (CMS-2567 and W-tags)

The California Department of Public Health (CDPH) is both the state licensing agency and the federal survey agency for ICFs: it grants the license and it surveys certified facilities for the Centers for Medicare & Medicaid Services (CMS).

Under 42 CFR 442.109, each ICF/IID must be surveyed no later than 15 months after its last survey, and the statewide average interval must be 12 months or less. Surveys also happen when CDPH investigates a complaint or an incident the facility reported.

CMS's surveyor guidance (State Operations Manual, Appendix J) describes the survey levels:

Fundamental survey

The default for recertification. Surveyors check key standards, mostly by observing.

Extended survey

Triggered when standard-level deficiencies suggest a whole Condition of Participation may be out of compliance.

Full survey

Required for initial certification, or when warranted. Covers all eight Conditions of Participation.

Life Safety Code survey

A separate fire-safety survey at initial certification and recertification.

On a facility page, each survey shows its date, its type as CMS records it (Recertification, Complaint, Initial, Focused Infection Control and others, sometimes combined) and its event ID.

Federal ICF/IID requirements are grouped into eight Conditions of Participation in 42 CFR 483.410 to 483.480:

1. Governing body and management (483.410)
2. Client protections (483.420)
3. Facility staffing (483.430)
4. Active treatment services (483.440)
5. Client behavior and facility practices (483.450)
6. Health care services (483.460)
7. Physical environment (483.470)
8. Dietetic services (483.480)

Each federal requirement has a tag number. Appendix J numbers the ICF/IID requirements as W-tags; CMS's data writes them with four digits (W0331 is the same tag as W331). A few examples from Appendix J:

• W159: the Qualified Intellectual Disabilities Professional (QIDP) integrates, coordinates and monitors each client's active treatment (483.430(a)).
• W186: the facility has enough direct care staff (483.430(d)(1)).
• W196: each client receives a continuous active treatment program (483.440(a)(1)).

Two other families appear on ICF surveys: E-tags for emergency preparedness (42 CFR 483.475) and K-tags for the Life Safety Code. A W0000 "initial comments" entry isn't a deficiency; it's the survey's opening note, which often says what kind of survey it was and whether any deficiencies were found. This site shows it as the survey note.

The Deficiency Finder searches every California ICF's federal findings by tag or by words in the narrative.

ICF/IID surveys have no scope-and-severity grid like nursing homes do. The one severity signal is the level:

Standard-level

A single requirement wasn't met.

Condition-level

The facility was found out of compliance with a whole Condition of Participation — the most serious finding on an ICF/IID survey.

Condition-level problems carry federal consequences. Under 42 CFR 442.117, when a deficiency poses immediate jeopardy and a Condition isn't met, certification must be terminated. Under 442.118, when Conditions aren't met, payment for new admissions may be denied after the facility has been given up to 60 days to correct.

1. Check the form. A federal 2567 shows W-, E- or K-tags. A state citation is a different document with a class (AA, A or B) and a penalty — see State citations AA, A and B, explained.
2. Check the level. A condition-level finding is the one to read first.
3. Check the date and the survey type. A recertification survey looks at the facility broadly; a complaint survey looks only at the complaint, and its note usually says so.
4. Read the narrative. It says which requirement wasn't met, for how many clients, and what the surveyors saw, heard and read. Residents are identified only by number ("Client 1").
5. Remember the scale. Most California ICFs are small homes (the median has 6 beds), and surveyors look at outcomes for each person, so one deficiency can involve a single resident.
6. Look for repeats. The same tag cited at several surveys suggests the problem wasn't fixed at the root.
7. Read the plan of correction. It isn't in CMS's bulk file, but it is filed with the official 2567. Each survey on this site links to the official copy on CDPH's CalHealthFind.

• State licensing deficiencies (from state surveys) aren't in CMS's file. CalHealthFind shows them.
• Complaints and facility-reported incidents themselves (the intake, the allegation and whether it was substantiated) are on CalHealthFind only.
• ICFs that are licensed but not certified for Medi-Cal have no federal surveys at all.
• CMS says its ICF/IID data is reliable through March 19, 2026, while its systems migrate; later surveys may be missing.