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  2. /Where nursing-home penalties concentrate: a repeat-citation story, 2026
FINANCIAL DISTRESS · ISSUE 076
cms-nursing-home-compareOriginal Research

Where nursing-home penalties concentrate: a repeat-citation story, 2026

Between May 2023 and April 2026, CMS imposed $459.3M in civil money penalties and 2,513 payment denials on 6,884 nursing facilities. Enforcement concentrates: the 53.7% of penalized facilities cited more than once carry 80.1% of the fine dollars and 90.6% of the payment denials — the half cited once drew a fifth of the money.

BY FONTEUM RESEARCH BUREAU · JUNE 16, 2026 · 9 MIN READ · ASSERTED VIA SLSA L3REVIEWED BY DR. JENNIFER MONTECILLO, MDSNAPSHOT 2026-06-16 · DOI 10.5072/fonteum/nursing-home-penalty-concentration-2026 · LAST UPDATED JUNE 16, 2026
CMS Nursing Home Compare · 2026-06-16
Reviewed by Dr. Jennifer Montecillo, MD, non-practicing medical reviewer. Gullas College of Medicine, 2019. Non-practicing medical reviewer focused on source interpretation, terminology, and limitations language. About our reviewers →
Reproduce this study →
CMS nursing-home fine dollars by state, top six, 2023–2026cms-nursing-home-compare · 2026-06-16
Illinois
66149870
Texas
59272333
California
30757146
Ohio
21223444
Florida
19252995
Missouri
17073306
Built on CMS Nursing Home Compare · snapshot 2026-06-16 · reproducible · re-derive the figures yourself
Key findings
80.1%
of all fine dollars fall on the 3,699 nursing facilities (53.7% of those penalized) that CMS cited more than once in three years; those same facilities carry 2,277 of the 2,513 payment denials (90.6%). The 46.3% cited just once drew only a fifth of the money
cms-nursing-home-compare · CMS
$459.3M
in civil money penalties across 13,764 fine actions, plus 2,513 payment-denial actions, fell on 6,884 Medicare/Medicaid-certified facilities between May 2023 and April 2026. The median fine was $14,576; the largest single fine was $713,795
cms-nursing-home-compare · CMS
716
facilities — 10.4% of those penalized — drew five or more enforcement actions in the three-year window. They are the most-cited tier and carry 28.4% of the fine dollars and 35.0% of the payment denials
cms-nursing-home-compare · CMS
$66.1M
in fines fell on Illinois facilities, 14.4% of the national total and more than any other state, across 467 facilities and 496 payment denials — roughly one in five payment denials nationwide — at an average fine of $50,190, the highest among the largest enforcement states
cms-nursing-home-compare · CMS
16,277
enforcement actions across 53 states and territories make up the published file, CMS release dated 2026-05-01, keyed to 6,884 distinct facility CCNs. Every figure is a count or sum over published records — no individual facility is named, ranked, or scored
cms-nursing-home-compare · CMS
On this page
Most penalized facilities are penalized more than onceThe dollars follow the same curveWhere enforcement concentratesPayment denials are the severe tierWhat one row actually isMethodologyLimitationsSources

CMS keeps a public ledger of the financial enforcement actions it takes against the nation's Medicare/Medicaid-certified nursing facilities. The Civil Money Penalties file, republished quarterly through the agency's data catalog, lists each action by facility, with the penalty type, the fine amount, the payment-denial length where one applies, and the date. CMS issues these penalties; this study does not. Read the current file and one pattern dominates: the money and the severe actions do not spread evenly across penalized facilities — they pile onto the ones CMS cites again and again.

Most penalized facilities are penalized more than once

Of the 6,884 facilities CMS penalized between May 2023 and April 2026, the 3,699 cited more than once — 53.7% — account for 80.1% of all fine dollars and 2,277 of the 2,513 payment denials (90.6%). The 46.3% of facilities cited just once drew about a fifth of the money.

Penalties per facilityFacilities% of facilitiesFine dollars% of dollarsPayment denials% of denials
13,18546.3%$91,417,53419.9%2369.4%
2–42,98343.3%$237,324,67351.7%1,39755.6%
5–95978.7%$108,506,78623.6%73729.3%
10+1191.7%$22,088,8144.8%1435.7%

Source: CMS Civil Money Penalties, facilities grouped by number of enforcement actions, source release 2026-05-01.

The curve is steep at the top. A tier of 716 facilities — 10.4% of those penalized — drew five or more actions in three years, and carries 28.4% of the fine dollars and 35.0% of the payment denials. Enforcement is not a once-and-corrected event spread across the field; it returns to a minority of facilities. That is what concentration means here: the same CCNs recur, and the severe remedy — denial of payment for new admissions — recurs with them.

A civil money penalty records a CMS enforcement action, not a Fonteum judgment. It marks that the agency cited a facility and set an amount — and says nothing this study adds about the care a resident receives there today.

The dollars follow the same curve

The fine amounts are themselves heavily skewed: the median fine is $14,576, but the 1,138 fines of $100,000 or more — 8.3% of all fine actions — carry 40.7% of every dollar. The distribution has a long, thin tail of very large penalties on top of a thick base of small ones.

Fine sizeStatistic
Median fine$14,576
90th-percentile fine$86,392
99th-percentile fine$229,243
Largest single fine$713,795
Fines ≥ $100,0001,138 (8.3% of fine actions)
Share of dollars from fines ≥ $100,00040.7%

Source: CMS Civil Money Penalties, distribution of the 13,764 fine actions by amount, source release 2026-05-01.

Most fine actions are modest — 4,753 of them are under $10,000 — and reflect per-instance or short per-day citations. The dollars, though, are made elsewhere: a few large per-day penalties accumulated over a long uncorrected period account for a disproportionate share of the $459.3M total. The skew in dollars and the concentration by facility are two views of the same fact — sustained, repeated noncompliance is where the cost lands.

Where enforcement concentrates

Illinois facilities drew $66.1M in fines — 14.4% of the national total and more than any other state — across 467 facilities and 496 payment denials, roughly one in five of every payment denial in the country. Geography matters as much as facility history.

StateFacilitiesFine dollars% of dollarsPayment denialsAverage fine
Illinois467$66,149,87014.4%496$50,190
Texas826$59,272,33312.9%162$32,074
California526$30,757,1466.7%287$25,760
Ohio318$21,223,4444.6%169$40,580
Florida284$19,252,9954.2%23$28,650
Missouri233$17,073,3063.7%151$34,011
Pennsylvania298$17,000,1203.7%58$31,717
North Carolina249$16,499,0133.6%82$31,790

Source: CMS Civil Money Penalties, the eight states with the most fine dollars, source release 2026-05-01.

Two different enforcement mixes are visible in the table. Illinois combines a high average fine ($50,190) with a heavy use of payment denial — its 496 denials are far above any other state and lift the severe-action share well past its share of facilities. Texas penalizes the most facilities (826) but at a lower average fine and far fewer denials. Florida shows the opposite of Illinois: $19.3M in fines but only 23 payment denials, an almost purely monetary enforcement posture. The state pattern reflects how each CMS regional office and state survey agency applies the same federal remedies, not a Fonteum ranking of state quality.

Payment denials are the severe tier

The 2,513 payment denials in the file are the more serious remedy, and they cluster with the repeat-cited facilities: 90.6% of them fall on facilities CMS cited more than once. A payment denial suspends Medicare/Medicaid reimbursement for new admissions until a facility corrects its deficiencies; in this file each one lasts 27 days on average, with a median of 19 days and a maximum of 458. Unlike a fine, CMS does not attach a dollar figure to a payment denial, so the $459.3M total counts fine actions only and the denials sit alongside it as a separate severity signal.

The denials' concentration is the sharpest version of the study's headline. A monetary penalty can be a one-off; a payment denial signals CMS judged a facility's noncompliance serious enough to restrict its funded admissions. That CMS reaches for that tool overwhelmingly at facilities it has cited before is the clearest sign that financial enforcement tracks a recurring minority rather than a rotating cast.

What one row actually is

Each row in cms_civil_money_penalties is one CMS enforcement action: a facility CCN and name, its city and state, the penalty type, the fine amount (for fine actions) or the payment-denial length, and the date. The file is keyed to the facility's CMS Certification Number, not to any individual provider — it carries no NPI — so penalties join to facilities, never to a named clinician. The published file is the current enforcement record CMS releases each quarter; counting and grouping these rows is the entire method here. Every figure in this study is a count, sum, or percentage at the facility-tally, fine-size, state, or penalty-type level. No facility is named, ranked, or scored.

Methodology

All figures are direct aggregations over the cms_civil_money_penalties table, populated from the CMS Civil Money Penalties public-use file published through the CMS data catalog (data.cms.gov, dataset g6vv-u9sr). The table holds 16,277 enforcement actions — 13,764 fine actions totaling $459,337,807 and 2,513 payment-denial actions — across 6,884 distinct facility CCNs in 53 states and territories; source release 2026-05-01, covering actions dated May 17, 2023 through April 17, 2026; public, read-only; license US-Government-Works.

This study reads the published file as a whole — every row is an enforcement action CMS records against a certified facility — and aggregates it four ways: by penalty type, by the number of actions per facility (the concentration view), by fine amount, and by state. The repeat-citation groups count distinct CCNs; a facility appears in exactly one group based on its total action count over the window. Dollar figures sum fine_amount over fine actions only, because CMS publishes no separate amount for payment-denial actions. Because these are counts and sums over a published file, every figure is exact as of the snapshot rather than estimated. Methodology version: cms-cmp/v1. The source-provenance contract is documented in the provenance methodology.

Limitations

  • A CMS enforcement record, not a Fonteum assessment. Every penalty is a CMS enforcement action published by CMS. Fonteum does not impose fines, assess facility compliance, or make enforcement determinations. This study draws no conclusion about any facility from the presence of a penalty.
  • Aggregate and facility-tally only. Every figure is a count, sum, or percentage at the penalty-type, repeat-count, fine-size, or state level. No individual facility is named, ranked, or scored, and the file carries no provider NPI, so no penalty renders on any provider profile.
  • Enforcement history is not current condition. A penalty records a past survey citation. Many facilities correct deficiencies promptly; the file does not show whether a facility is in or out of compliance today. A single enforcement record is one regulatory signal and does not characterize a facility's overall quality.
  • Fine dollars exclude payment denials. The $459.3M total sums fine actions only. CMS attaches no separate dollar amount to a payment-denial action, so denials are counted and timed but carry no dollar figure.
  • Snapshot, not a trend model. Figures reflect the single file released 2026-05-01. CMS refreshes the file quarterly and adds, modifies, or closes records between releases, so totals shift; this study does not model change over time, and the partial-year tail of the window is not a complete year.
  • Penalty type and amount are CMS-defined. The penalty type, the fine amount, and the payment-denial trigger all follow CMS's published enforcement criteria. This study reports those values as recorded and does not replicate or audit the CMS enforcement methodology.

Sources

  • CMS — Civil Money Penalties (dataset g6vv-u9sr) — the quarterly public-use file behind every figure in this study.
  • CMS — Nursing homes, including rehab services — the federal certification and enforcement program under which these penalties are issued.
  • CMS — Civil money penalties and the enforcement process — how CMS applies fines and payment denials to facilities found out of compliance.

The companion dataset page for CMS Civil Money Penalties lists the full schema and refresh cadence, and the CMS NH Penalties source page records the provenance. This is the financial-enforcement mirror of the OIG exclusion list, which bars providers from Medicare entirely and of the providers still enrolled despite an active exclusion; for how exclusion screening misses most state Medicaid bars see the exclusion gap, and for the shape of the exclusion list over time, why provider exclusions cluster around distressed operators.

Frequently asked questions

What is a CMS civil money penalty against a nursing home?
A civil money penalty (CMP) is a fine CMS imposes on a Medicare/Medicaid-certified nursing facility found out of compliance with federal Conditions of Participation. CMS can levy a per-day amount for an ongoing deficiency or a per-instance amount for a specific event. The penalty is a CMS enforcement determination; this study counts the published actions and does not assess any facility's compliance.
How concentrated is nursing-home enforcement?
Heavily. Of the 6,884 facilities penalized between May 2023 and April 2026, the 3,699 cited more than once — 53.7% — account for 80.1% of all fine dollars and 90.6% of the payment denials. The 46.3% of facilities cited just once drew about a fifth of the dollars. A smaller tier of 716 facilities cited five or more times carries 28.4% of the money and 35.0% of the denials.
What is the difference between a fine and a payment denial?
They are the two enforcement actions in the file. A fine is a monetary penalty: 13,764 fine actions total $459,337,807. A payment denial — a denial of payment for new admissions — suspends Medicare/Medicaid reimbursement until deficiencies are corrected and is the more severe remedy; there are 2,513 of them, lasting 27 days on average. CMS does not attach a separate dollar amount to a payment-denial action, so the dollar totals here cover fine actions only.
Which states have the most nursing-home penalties?
By fine dollars, Illinois leads with $66.1M (14.4% of the national total) across 467 facilities, followed by Texas ($59.3M) and California ($30.8M). Illinois also records 496 payment denials — roughly one in five of all denials nationwide — and the highest average fine among the largest states, $50,190 against a national median of $14,576.
Does a penalty mean a nursing home is unsafe today?
Not on its own. A penalty is a record that CMS cited a facility for a deficiency on a past survey and set an amount. Many facilities correct deficiencies promptly; the file does not show current condition, and a single enforcement record is one regulatory signal among many. This study draws no conclusion about the care at any facility and names none.
Is Fonteum issuing or assessing these penalties?
No. Every penalty in this study is a CMS enforcement action published by CMS. Fonteum does not impose fines, assess facility compliance, or make enforcement determinations. The study aggregates the published records — by penalty type, repeat-citation count, fine size, and state — and reports the counts and sums.
Can I reproduce these figures?
Yes. Every number is a direct count or sum over the public cms_civil_money_penalties table — CMS's Civil Money Penalties file, source release 2026-05-01 — with no modeling. The exact SQL for the penalty-type split, the per-facility concentration, the fine-size distribution, and the state breakdown is published in the reproducibility block below.

Who uses this data

The source data behind this study is public

Compliance teams, journalists, and researchers work from the same federal source families cited above — queried by NPI or facility identifier through Fonteum’s open dataset pages and API. Every figure traces to a frozen, downloadable snapshot you can reproduce yourself.

Browse CMS Nursing Home Compare→Query the API →How we built this →

Datasets used

CMS Nursing Home Compare→

Reproducibility

Every claim, reproducible

The SQL+
nursing-home-penalty-concentration-2026.sql
-- WHERE Medicare's nursing-home civil money penalties concentrate — and why it
-- is a repeat-citation story. Fully reproducible query.
--
-- Question: of the civil money penalties (CMPs) and payment denials CMS has
-- imposed on Medicare/Medicaid-certified nursing facilities, how are the dollars
-- and the severe actions distributed across facilities, fine sizes, and states?
-- The lead figure: of the 6,884 facilities penalized between May 2023 and April
-- 2026, the 3,699 cited more than once (53.7%) carry 80.1% of all fine dollars
-- and 90.6% of the payment denials. A penalty is a CMS enforcement action, NOT
-- a Fonteum judgment, fraud signal, or assessment of current facility quality.
--
-- Source:
--   public.cms_civil_money_penalties — CMS "Civil Money Penalties" public-use
--     file, published quarterly via the CMS data catalog (data.cms.gov, dataset
--     g6vv-u9sr). 16,277 enforcement actions; source release 2026-05-01.
--     Public, read-only. License: US-Government-Works (17 U.S.C. Sec. 105).
--     methodology_version = 'cms-cmp/v1'.
--
-- Universe: this study reads the published file AS A WHOLE — every row is one
--   enforcement action CMS records against a certified facility, keyed to the
--   facility CMS Certification Number (CCN). The file carries NO provider NPI;
--   penalties join to facilities, never to a named clinician. It is the current
--   enforcement record CMS releases each quarter, not a cumulative history.
--
-- Counting note: two penalty types appear. A "Fine" carries a fine_amount; a
--   "Payment Denial" suspends Medicare/Medicaid payment for new admissions and
--   carries a payment_denial_days length but NO dollar amount. All dollar totals
--   below sum fine actions only. No individual facility is named in the study.

-- ============================================================================
-- (1) Universe reconciliation — the published file at a glance.
-- ============================================================================
SELECT
  count(*)                                                          AS actions,
  count(DISTINCT ccn)                                               AS distinct_ccn,
  count(DISTINCT state)                                             AS states,
  count(*) FILTER (WHERE penalty_type = 'Fine')                     AS fine_actions,
  round(sum(fine_amount) FILTER (WHERE penalty_type = 'Fine'))      AS total_fine_usd,
  count(*) FILTER (WHERE penalty_type = 'Payment Denial')           AS payment_denials,
  min(penalty_date)                                                 AS earliest_action,
  max(penalty_date)                                                 AS latest_action,
  max(source_release_date)                                          AS source_release
FROM public.cms_civil_money_penalties;
--  actions 16,277 · distinct_ccn 6,884 · states 53 · fine_actions 13,764
--  total_fine_usd 459,337,807 · payment_denials 2,513
--  earliest 2023-05-17 · latest 2026-04-17 · source_release 2026-05-01

-- ============================================================================
-- (2) HEADLINE: enforcement is concentrated on repeat-cited facilities. Roll up
--     to the facility (CCN), bucket by how many actions each facility drew, and
--     read the share of dollars and payment denials per bucket. The 2-or-more
--     buckets together = 53.7% of facilities, 80.1% of dollars, 90.6% of denials.
-- ============================================================================
WITH fac AS (
  SELECT
    ccn,
    count(*)                                                        AS actions,
    sum(coalesce(fine_amount, 0))                                   AS fines,
    count(*) FILTER (WHERE penalty_type = 'Payment Denial')         AS denials
  FROM public.cms_civil_money_penalties
  GROUP BY ccn
), bucketed AS (
  SELECT
    CASE WHEN actions = 1 THEN '1'
         WHEN actions BETWEEN 2 AND 4 THEN '2-4'
         WHEN actions BETWEEN 5 AND 9 THEN '5-9'
         ELSE '10+' END                                             AS penalties_per_facility,
    actions, fines, denials
  FROM fac
)
SELECT
  penalties_per_facility,
  count(*)                                                          AS facilities,
  round(100.0 * count(*) / sum(count(*)) OVER (), 1)                AS pct_facilities,
  round(sum(fines))                                                 AS fine_dollars,
  round(100.0 * sum(fines) / sum(sum(fines)) OVER (), 1)            AS pct_dollars,
  sum(denials)                                                      AS payment_denials,
  round(100.0 * sum(denials) / sum(sum(denials)) OVER (), 1)        AS pct_denials
FROM bucketed
GROUP BY penalties_per_facility
ORDER BY min(actions);
--  1    3,185  46.3%  $ 91,417,534  19.9%  236   9.4%
--  2-4  2,983  43.3%  $237,324,673  51.7% 1,397  55.6%
--  5-9    597   8.7%  $108,506,786  23.6%  737  29.3%
--  10+    119   1.7%  $ 22,088,814   4.8%  143   5.7%
--  cited >1x  = 3,699 facilities (53.7%), 80.1% of dollars, 2,277 denials (90.6%)
--  cited >=5x =   716 facilities (10.4%), 28.4% of dollars,   880 denials (35.0%)

-- ============================================================================
-- (3) The fine-amount distribution is itself skewed: a thick base of small fines
--     and a thin tail of very large ones. The median fine is $14,576, but the
--     1,138 fines of $100k+ (8.3% of fine actions) carry 40.7% of every dollar.
-- ============================================================================
SELECT
  round(percentile_cont(0.5)  WITHIN GROUP (ORDER BY fine_amount)
        FILTER (WHERE fine_amount > 0))                             AS median_fine,
  round(percentile_cont(0.9)  WITHIN GROUP (ORDER BY fine_amount)
        FILTER (WHERE fine_amount > 0))                             AS p90_fine,
  round(percentile_cont(0.99) WITHIN GROUP (ORDER BY fine_amount)
        FILTER (WHERE fine_amount > 0))                             AS p99_fine,
  max(fine_amount)                                                  AS max_fine,
  count(*) FILTER (WHERE fine_amount >= 100000)                     AS fines_100k_plus,
  round(100.0 * sum(fine_amount) FILTER (WHERE fine_amount >= 100000)
        / sum(fine_amount) FILTER (WHERE fine_amount > 0), 1)       AS pct_dollars_100k_plus,
  count(*) FILTER (WHERE fine_amount > 0 AND fine_amount < 10000)   AS fines_under_10k
FROM public.cms_civil_money_penalties;
--  median_fine $14,576 · p90 $86,392 · p99 $229,243 · max $713,795
--  fines_100k_plus 1,138 · pct_dollars_100k_plus 40.7% · fines_under_10k 4,753

-- ============================================================================
-- (4) WHERE the dollars are — top 8 states by total fine dollars, with each
--     state's facility count, payment denials, and average fine. Illinois leads
--     ($66.1M, 14.4% of all dollars) and records 496 payment denials — about one
--     in five nationwide — at the highest average fine of the largest states.
-- ============================================================================
SELECT
  state,
  count(DISTINCT ccn)                                               AS facilities,
  round(sum(coalesce(fine_amount, 0)))                              AS fine_dollars,
  round(100.0 * sum(coalesce(fine_amount, 0))
        / sum(sum(coalesce(fine_amount, 0))) OVER (), 1)            AS pct_dollars,
  count(*) FILTER (WHERE penalty_type = 'Payment Denial')           AS payment_denials,
  round(avg(fine_amount) FILTER (WHERE fine_amount > 0))            AS avg_fine
FROM public.cms_civil_money_penalties
WHERE state IS NOT NULL
GROUP BY state
ORDER BY fine_dollars DESC
LIMIT 8;
--  IL 467 $66,149,870 14.4% 496 $50,190 · TX 826 $59,272,333 12.9% 162 $32,074
--  CA 526 $30,757,146  6.7% 287 $25,760 · OH 318 $21,223,444  4.6% 169 $40,580
--  FL 284 $19,252,995  4.2%  23 $28,650 · MO 233 $17,073,306  3.7% 151 $34,011
--  PA 298 $17,000,120  3.7%  58 $31,717 · NC 249 $16,499,013  3.6%  82 $31,790

-- ============================================================================
-- (5) Payment denials are the severe tier — denial of payment for new admissions
--     until deficiencies are corrected. They cluster with repeat-cited
--     facilities (90.6% fall on facilities cited >1x, see query 2) and run 27
--     days on average. CMS attaches no dollar amount to a denial action.
-- ============================================================================
SELECT
  count(*) FILTER (WHERE payment_denial_days > 0)                   AS payment_denials,
  round(avg(payment_denial_days) FILTER (WHERE payment_denial_days > 0)) AS avg_days,
  percentile_cont(0.5) WITHIN GROUP (ORDER BY payment_denial_days)
        FILTER (WHERE payment_denial_days > 0)                      AS median_days,
  max(payment_denial_days)                                          AS max_days
FROM public.cms_civil_money_penalties;
--  payment_denials 2,513 · avg_days 27 · median_days 19 · max_days 458

-- ============================================================================
-- (6) The action window by year, for context only (NOT a trend model). The file
--     spans a partial 2023 (from May 17) through a partial 2026 (to April 17),
--     so the first and last years are incomplete. Counts are by penalty_date.
-- ============================================================================
SELECT
  extract(year FROM penalty_date)::int                              AS action_year,
  count(*)                                                          AS actions,
  count(*) FILTER (WHERE penalty_type = 'Fine')                     AS fine_actions,
  round(sum(coalesce(fine_amount, 0)))                              AS fine_dollars,
  count(*) FILTER (WHERE penalty_type = 'Payment Denial')           AS payment_denials
FROM public.cms_civil_money_penalties
GROUP BY action_year
ORDER BY action_year;
--  2023 5,539 4,876 $117,210,368 663 (partial, from 2023-05-17)
--  2024 6,170 5,098 $183,989,128 1,072
--  2025 4,162 3,423 $143,381,741 739
--  2026   406   367 $ 14,756,570  39 (partial, to 2026-04-17)
The snapshot+
dataset_idcms-nursing-home-compare
snapshot_date2026-06-16
sha256
doi10.5072/fonteum/nursing-home-penalty-concentration-2026
slsa_provenance_url
The JOINs+
universe: the published file as a whole                                       -- 16,277 enforcement actions, 6,884 facility CCNs, source release 2026-05-01
penalty type = penalty_type                                                   -- Fine 13,764 ($459,337,807); Payment Denial 2,513
per-facility rollup = GROUP BY ccn                                            -- 3,185 facilities cited once; 3,699 cited 2+ times (53.7%)
repeat concentration = facilities with >1 action                             -- 80.1% of dollars, 2,277 of 2,513 denials (90.6%)
fine-size distribution: percentile_cont over fine_amount                      -- median $14,576; 1,138 fines >= $100k = 40.7% of dollars
state mix: GROUP BY state                                                     -- IL $66.1M (14.4%), 496 denials; TX $59.3M; CA $30.8M
payment-denial duration = payment_denial_days                                -- mean 27 days, median 19, max 458 across all 2,513 denials
The pipeline version+
git_sha
slsa_provenance
methodology_versioncms-cmp/v1

Reproduce this

Run the exact query against the frozen 2026-06-16.

-- WHERE Medicare's nursing-home civil money penalties concentrate — and why it -- is a repeat-citation story. Fully reproducible query. -- -- Question: of the civil money penalties (CMPs) and payment denials CMS has -- imposed on Medicare/Medicaid-certified nursing facilities, how are the dollars -- and the severe actions distributed across facilities, fine sizes, and states? -- The lead figure: of the 6,884 facilities penalized between May 2023 and April -- 2026, the 3,699 cited more than once (53.7%) carry 80.1% of all fine dollars -- and 90.6% of the payment denials. A penalty is a CMS enforcement action, NOT -- a Fonteum judgment, fraud signal, or assessment of current facility quality. -- -- Source: -- public.cms_civil_money_penalties — CMS "Civil Money Penalties" public-use -- file, published quarterly via the CMS data catalog (data.cms.gov, dataset -- g6vv-u9sr). 16,277 enforcement actions; source release 2026-05-01. -- Public, read-only. License: US-Government-Works (17 U.S.C. Sec. 105). -- methodology_version = 'cms-cmp/v1'. -- -- Universe: this study reads the published file AS A WHOLE — every row is one -- enforcement action CMS records against a certified facility, keyed to the -- facility CMS Certification Number (CCN). The file carries NO provider NPI; -- penalties join to facilities, never to a named clinician. It is the current -- enforcement record CMS releases each quarter, not a cumulative history. -- -- Counting note: two penalty types appear. A "Fine" carries a fine_amount; a -- "Payment Denial" suspends Medicare/Medicaid payment for new admissions and -- carries a payment_denial_days length but NO dollar amount. All dollar totals -- below sum fine actions only. No individual facility is named in the study. -- ============================================================================ -- (1) Universe reconciliation — the published file at a glance. -- ============================================================================ SELECT count(*) AS actions, count(DISTINCT ccn) AS distinct_ccn, count(DISTINCT state) AS states, count(*) FILTER (WHERE penalty_type = 'Fine') AS fine_actions, round(sum(fine_amount) FILTER (WHERE penalty_type = 'Fine')) AS total_fine_usd, count(*) FILTER (WHERE penalty_type = 'Payment Denial') AS payment_denials, min(penalty_date) AS earliest_action, max(penalty_date) AS latest_action, max(source_release_date) AS source_release FROM public.cms_civil_money_penalties; -- actions 16,277 · distinct_ccn 6,884 · states 53 · fine_actions 13,764 -- total_fine_usd 459,337,807 · payment_denials 2,513 -- earliest 2023-05-17 · latest 2026-04-17 · source_release 2026-05-01 -- ============================================================================ -- (2) HEADLINE: enforcement is concentrated on repeat-cited facilities. Roll up -- to the facility (CCN), bucket by how many actions each facility drew, and -- read the share of dollars and payment denials per bucket. The 2-or-more -- buckets together = 53.7% of facilities, 80.1% of dollars, 90.6% of denials. -- ============================================================================ WITH fac AS ( SELECT ccn, count(*) AS actions, sum(coalesce(fine_amount, 0)) AS fines, count(*) FILTER (WHERE penalty_type = 'Payment Denial') AS denials FROM public.cms_civil_money_penalties GROUP BY ccn ), bucketed AS ( SELECT CASE WHEN actions = 1 THEN '1' WHEN actions BETWEEN 2 AND 4 THEN '2-4' WHEN actions BETWEEN 5 AND 9 THEN '5-9' ELSE '10+' END AS penalties_per_facility, actions, fines, denials FROM fac ) SELECT penalties_per_facility, count(*) AS facilities, round(100.0 * count(*) / sum(count(*)) OVER (), 1) AS pct_facilities, round(sum(fines)) AS fine_dollars, round(100.0 * sum(fines) / sum(sum(fines)) OVER (), 1) AS pct_dollars, sum(denials) AS payment_denials, round(100.0 * sum(denials) / sum(sum(denials)) OVER (), 1) AS pct_denials FROM bucketed GROUP BY penalties_per_facility ORDER BY min(actions); -- 1 3,185 46.3% $ 91,417,534 19.9% 236 9.4% -- 2-4 2,983 43.3% $237,324,673 51.7% 1,397 55.6% -- 5-9 597 8.7% $108,506,786 23.6% 737 29.3% -- 10+ 119 1.7% $ 22,088,814 4.8% 143 5.7% -- cited >1x = 3,699 facilities (53.7%), 80.1% of dollars, 2,277 denials (90.6%) -- cited >=5x = 716 facilities (10.4%), 28.4% of dollars, 880 denials (35.0%) -- ============================================================================ -- (3) The fine-amount distribution is itself skewed: a thick base of small fines -- and a thin tail of very large ones. The median fine is $14,576, but the -- 1,138 fines of $100k+ (8.3% of fine actions) carry 40.7% of every dollar. -- ============================================================================ SELECT round(percentile_cont(0.5) WITHIN GROUP (ORDER BY fine_amount) FILTER (WHERE fine_amount > 0)) AS median_fine, round(percentile_cont(0.9) WITHIN GROUP (ORDER BY fine_amount) FILTER (WHERE fine_amount > 0)) AS p90_fine, round(percentile_cont(0.99) WITHIN GROUP (ORDER BY fine_amount) FILTER (WHERE fine_amount > 0)) AS p99_fine, max(fine_amount) AS max_fine, count(*) FILTER (WHERE fine_amount >= 100000) AS fines_100k_plus, round(100.0 * sum(fine_amount) FILTER (WHERE fine_amount >= 100000) / sum(fine_amount) FILTER (WHERE fine_amount > 0), 1) AS pct_dollars_100k_plus, count(*) FILTER (WHERE fine_amount > 0 AND fine_amount < 10000) AS fines_under_10k FROM public.cms_civil_money_penalties; -- median_fine $14,576 · p90 $86,392 · p99 $229,243 · max $713,795 -- fines_100k_plus 1,138 · pct_dollars_100k_plus 40.7% · fines_under_10k 4,753 -- ============================================================================ -- (4) WHERE the dollars are — top 8 states by total fine dollars, with each -- state's facility count, payment denials, and average fine. Illinois leads -- ($66.1M, 14.4% of all dollars) and records 496 payment denials — about one -- in five nationwide — at the highest average fine of the largest states. -- ============================================================================ SELECT state, count(DISTINCT ccn) AS facilities, round(sum(coalesce(fine_amount, 0))) AS fine_dollars, round(100.0 * sum(coalesce(fine_amount, 0)) / sum(sum(coalesce(fine_amount, 0))) OVER (), 1) AS pct_dollars, count(*) FILTER (WHERE penalty_type = 'Payment Denial') AS payment_denials, round(avg(fine_amount) FILTER (WHERE fine_amount > 0)) AS avg_fine FROM public.cms_civil_money_penalties WHERE state IS NOT NULL GROUP BY state ORDER BY fine_dollars DESC LIMIT 8; -- IL 467 $66,149,870 14.4% 496 $50,190 · TX 826 $59,272,333 12.9% 162 $32,074 -- CA 526 $30,757,146 6.7% 287 $25,760 · OH 318 $21,223,444 4.6% 169 $40,580 -- FL 284 $19,252,995 4.2% 23 $28,650 · MO 233 $17,073,306 3.7% 151 $34,011 -- PA 298 $17,000,120 3.7% 58 $31,717 · NC 249 $16,499,013 3.6% 82 $31,790 -- ============================================================================ -- (5) Payment denials are the severe tier — denial of payment for new admissions -- until deficiencies are corrected. They cluster with repeat-cited -- facilities (90.6% fall on facilities cited >1x, see query 2) and run 27 -- days on average. CMS attaches no dollar amount to a denial action. -- ============================================================================ SELECT count(*) FILTER (WHERE payment_denial_days > 0) AS payment_denials, round(avg(payment_denial_days) FILTER (WHERE payment_denial_days > 0)) AS avg_days, percentile_cont(0.5) WITHIN GROUP (ORDER BY payment_denial_days) FILTER (WHERE payment_denial_days > 0) AS median_days, max(payment_denial_days) AS max_days FROM public.cms_civil_money_penalties; -- payment_denials 2,513 · avg_days 27 · median_days 19 · max_days 458 -- ============================================================================ -- (6) The action window by year, for context only (NOT a trend model). The file -- spans a partial 2023 (from May 17) through a partial 2026 (to April 17), -- so the first and last years are incomplete. Counts are by penalty_date. -- ============================================================================ SELECT extract(year FROM penalty_date)::int AS action_year, count(*) AS actions, count(*) FILTER (WHERE penalty_type = 'Fine') AS fine_actions, round(sum(coalesce(fine_amount, 0))) AS fine_dollars, count(*) FILTER (WHERE penalty_type = 'Payment Denial') AS payment_denials FROM public.cms_civil_money_penalties GROUP BY action_year ORDER BY action_year; -- 2023 5,539 4,876 $117,210,368 663 (partial, from 2023-05-17) -- 2024 6,170 5,098 $183,989,128 1,072 -- 2025 4,162 3,423 $143,381,741 739 -- 2026 406 367 $ 14,756,570 39 (partial, to 2026-04-17)

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Fonteum Research Bureau (2026). Where nursing-home penalties concentrate: a repeat-citation story, 2026. CMS Nursing Home Compare, snapshot 2026-06-16. https://fonteum.com/research/nursing-home-penalty-concentration-2026

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