What CMS's 2025 Rule Updates Mean for Hospital Complaints and Grievances

When hospitals lack structured complaint tracking systems, the consequences extend far beyond administrative inconvenience. Missed follow-up deadlines, incomplete documentation, and the inability to identify trends can result in Joint Commission citations, Centers for Medicare & Medicaid Services (CMS) survey deficiencies, and most critically, repeated harm to patients. CMS’s latest announcement about enhanced complaint tracking reinforces a clear trajectory toward centralized, traceable systems that ensure timely response, complete documentation, and defined accountability.

What Was The Latest Update To CMS Grievance Response Requirements?

In a September 2025 memo, CMS announced enhancements to the Health Plan Management System (HPMS) Complaints Tracking Module (CTM) that took effect on October 31, 2025. The CTM update introduced multiple enhancements involving structured data fields, document upload capabilities, searchable records, and application programming interface (API) integration.

What Are The Enhancements And How Do They Impact Grievance Management?

The CTM applies to Medicare Advantage (MA) plan sponsors, Cost plan sponsors, Programs of All-Inclusive Care for the Elderly (PACE) sponsors, Demonstration sponsors, and Part D plan sponsors,  not hospitals. However, its emphasis on structured, searchable, uploadable data aligns with what hospital surveyors look for under 42 CFR 482.13 and the State Operations Manual Appendix A. Hospital Quality leaders should view CTM’s direction as a signal for the type of auditable workflows that support compliance, not as hospital-binding requirements.

Enhancements within the CTM include:

• Streamlined data reporting with multi-document upload capability.
• Additional data fields intended to enhance data tracking.
• Improved search functionality, allowing users to search via multiple data inputs (e.g., resolution date, first and last name).
• Expanded fields in the casework upload user interface and casework upload API.

What Are The Takeaways For Hospital Complaints And Grievances?

The HPMS memo is the latest signal from CMS that the agency is continuing to push for enhanced complaint data management across Medicare-participating entities. Under CMS Conditions of Participation, a grievance is a formal or written complaint about patient care that requires investigation and a written response, typically within seven days, or an updated timeline if the investigation cannot be completed within that period. While this article uses “complaints and grievances” to encompass the full spectrum of patient concerns, hospitals must maintain clear distinctions in their tracking systems to ensure compliance with CMS and Joint Commission requirements.

This focus is warranted: a 10-year analysis of 34,522 CMS hospital deficiencies found that most findings clustered within a small set of Conditions of Participation (CoPs), with patient rights listed among the six most frequently cited. The study also found that patient death was associated with 21% of surveys that resulted in immediate jeopardy determinations. The agency is putting the healthcare industry, including hospitals, on a clear trajectory to build structured, traceable systems that ensure prompt response, complete documentation, and clear accountability.

For hospital Quality leaders, this trajectory has immediate operational implications. During surveys, state agencies and Joint Commission reviewers expect to see auditable workflows that demonstrate timely acknowledgment, documented investigation steps, evidence of resolution within required timeframes, and analysis of complaint trends. Informal tracking systems create regulatory exposure because they cannot readily produce this documentation. Moreover, spreadsheet-based processes create coordination gaps: missed follow-up deadlines, unclear accountability for investigation steps, and an inability to quickly identify patterns that require system-level intervention.

Spreadsheets and informal tracking systems may not provide the structured data capture and reporting capabilities that support regulatory compliance. Purpose-built complaints and grievances management systems provide the structured approach that aligns with CMS’s regulatory direction.

How Does Grievance Tracking Software Align With Best Practices?

More than a decade ago, Stanford Health Care researchers identified the benefits of centralized complaint databases in “Creating a Patient Complaint Capture and Resolution Process to Incorporate Best Practices for Patient-Centered Representation,” published in the Joint Commission Journal on Quality and Patient Safety. That study identified several pillars of a high-functioning complaint management system including:

• Leadership accountability.
• Standardized workflows for tracking and responding to complaints.
• Centralized data management.

Since then, robust evidence supporting tech-reliant tracking systems continues to grow. A 2021 study from researchers at Cleveland Clinic shows how benchmarking patient complaint data can drive systems improvement. Focusing specifically on unsolicited patient complaints, the Cleveland Clinic’s Office of Patient Experience captured complaints in a dedicated software system, allowing for process improvement opportunities.

The key to success was formulaic and expansive data capture: complaints were collected and categorized by type of issue, unit location, severity, and individual employee involved. This structured approach enabled the hospital to identify patterns, set performance targets based on historical data, and prioritize resources to improve patient experiences.

Yet another study, this one from the Mayo Clinic, found that a dual approach to staff training can result in successful complaint-handling performance. It focused on:

• Training centered around communication. The program focused on interpersonal communication training for staff involved in fielding and handling complaints.
• Training around operational systems. Staff must be familiar with technological tracking and management systems in order to achieve optimal results.

The Regulatory Context for Hospital Complaints and Grievances

The CTM enhancements reflect a broader pattern across CMS and related agencies, applying similar rigor to grievance data through structured capture and auditable workflows. This trajectory builds on existing hospital requirements and points toward increasingly standardized data practices.

CMS already mandates extensive guidelines and requirements governing the hospital complaint process through the State Operations Manual Appendix A, Survey Protocol, Regulations and Interpretive Guidelines for Hospitals and Medicare Conditions of Participation. Organizations like The Joint Commission mandate similar requirements, with surveyors scrutinizing complaint tracking systems during accreditation reviews.

The trajectory becomes clearer when examining sister agencies. The Agency for Healthcare Research and Quality (AHRQ) already promotes structured data capture for event reporting through its “Common Formats” methodology. This framework, designed to capture safety events in hospitals and other settings, relies on structured data for event analysis, pattern and trending analysis, risk factor identification, the use of risk reduction methods, and data aggregation at organizational and national levels.

CMS also emphasizes documentation integrity in electronic health records (EHRs). As hospitals have invested in documentation integrity for EHR systems, applying the same rigor to complaint management represents a natural and necessary extension of existing quality infrastructure.

What Does Effective Grievance Management Look Like?

Ultimately, strengthening grievance management is part of patient safety oversight, not just a compliance concern. Based on the research evidence and regulatory requirements outlined above, a robust complaint oversight process typically includes such elements as:

• Customizable forms and workflows. With structured data capture, hospitals can quickly aggregate data, identify trends, and produce benchmarking reports. This speeds up the complaint response process, supports compliance with Conditions of Participation, and improves the patient experience.
• Automated notifications and reminders. Automated alerts keep Quality teams on track, keeping them within mandated timeframes. Task reminders prompt team members to address complaints or move complaints along the chain of command.
• Role-based work queues. Workflow solutions ensure that users only see the complaints and grievances relevant to their role, department, or assigned task, streamlining oversight and promoting focused accountability while keeping the process flowing.
• Real-time dashboards and KPIs. It’s vital for Quality leaders to have a single, accessible snapshot of the complaint management process. Dashboards track case volume, issue categories, task assignments, resolution statuses, and outcomes at a glance. They provide a clear look at the historical movement on a given complaint, logging outreach efforts, timelines, staff members involved, and the ultimate outcomes reached.

When evaluating systems to support these capabilities, Quality leaders should consider key criteria for selecting complaint and grievance tracking software that aligns with both current CMS requirements and the structured data direction signaled by recent CTM enhancements.

By integrating these features and treating complaint management documentation more like clinical documentation, hospitals can improve documentation reliability, enhance survey readiness, and make safety accountability a routine part of daily operations. Specialized complaint management software helps hospitals implement these structured approaches while meeting CMS expectations for complaint data management.

Moving Forward: Next Steps for Hospital Complaints and Grievances Management

The October 2025 CTM enhancements represent more than a technical update for health plans. They continue a broader CMS pattern of moving toward structured, auditable data practices across programs.

Quality and Patient Safety leaders should evaluate their current systems against three criteria:

• Documentation completeness and audit trails: Can your system generate comprehensive records showing complaint receipt, investigation steps, resolution actions, and response timeliness with built-in compliance timelines?
• Trend analysis and reporting capability: Can you quickly identify patterns by complaint type, unit, service line, or staff member using real-time dashboards and KPIs to prioritize improvement efforts?
• Survey readiness: Would your current documentation satisfy a surveyor’s request to demonstrate compliance with grievance response requirements, including timely acknowledgment and documented investigation steps?

Hospitals still relying on spreadsheets or email-based tracking should recognize that these approaches create unnecessary compliance risk and operational inefficiency. Purpose-built grievance management systems with customizable workflows, role-based work queues, and automated notifications enable hospitals to move from reactive tracking to proactive management.

Structured grievance management is not simply a regulatory checkbox. It is a patient safety imperative that enables organizations to identify system weaknesses, support staff accountability, and demonstrate their commitment to continuous improvement.

Hospitals adopting structured grievance management systems now gain a dual advantage: meeting current compliance expectations while preparing for future requirements. As CMS continues standardizing data expectations across programs, early adopters will lead rather than scramble to catch up.