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Many skilled nursing facilities are sitting on an untapped funding opportunity that many don’t even realize exists.
When the Centers for Medicare & Medicaid Services (CMS) fines a nursing facility for non-compliance, that money doesn’t disappear. A portion goes into a state-managed reinvestment pool and becomes available as grants that SNFs can apply for to fund care improvements.
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That’s the Civil Monetary Penalties (CMP) Reinvestment Program, and many SNFs across the U.S. aren’t using it. For example, Texas alone holds $34.3 million in unspent CMP funds — one of the largest reinvestment balances in the country. That means thousands of dollars are left on the table every year that could fund a variety of approved projects and make a real difference in any facility.
A September 2025 CMS update raised per-project funding caps across all categories to support enhanced quality improvement initiatives and encourage more funding requests from nursing facilities. The money is there to help make a difference for your residents.
In this blog, I’ll break down how the program works, what is likely to be funded, and why compliance initiatives are a smart use of the money.
What Are Civil Monetary Penalties (CMP)?
CMP refers to the monetary fine that Centers for Medicare and Medicaid Services impose when a skilled nursing facility fails to meet Medicare and Medicaid requirements. The fine is based either on every day they’re out of compliance or for each specific violation. Each of those fines against SNFs in the same state go to state-managed pools. That money can come back to your facility as a grant through the Civil Monetary Penalty Reinvestment Program.
What Is the CMP Reinvestment Program?
The CMP Reinvestment Program is a federal initiative through which CMS returns a portion of collected CMP funds to states and makes them available as grants for projects that directly improve resident care. Every state, including Washington, D.C., participates in this program.
Eligibility is fairly broad. CMS-certified long-term care facilities, consumer advocacy organizations, resident and family councils, academic institutions, state agencies, vendors, and professional associations are eligible for this grant money.
You can apply even if your facility hasn’t received a CMP fine. All you need is a qualifying project. But it’s important to keep in mind that most application windows only open once or twice a year, sometimes for only a few days at a time.
These windows vary from state to state. While the specific dates will likely change each year, you can expect some consistency with the general timeframes. For example, Texans can typically expect their application windows to open around January and July of each year.
What Can CMP Funding Pay For?
According to federal law, CMP funds can be used to pay for projects that directly benefit nursing home residents. Eligible projects can run up to 36 months and receive up to about $500 for each month.
If a project falls in one of the following categories, it is eligible for funding:
- Assistance for facilities that close to or are currently decertified
- Mental and behavioral health projects for nursing home residents
- Resident and family council support
- Training programs
- Technical assistance for quality assurance and performance improvement
- Innovative resident engagement programs
- Workforce enhancements
- Tools and technologies that enhance residents’ quality of life
How Can SNFs Leverage CMP Funding?
Compliance improvements are great candidates for CMP funding because they directly address the root cause of citations. Investing in any of the projects listed below doesn’t just satisfy CMS requirements. It reduces the likelihood of future violations, which in turn protects residents and keeps your facility survey-ready.
- Staff education aligned to CMS regulatory requirements, including joint training programs for facility staff and surveyors to ensure your team understands what CMS expects
- Workforce training and competency development, such as onboarding and skills verification to keep your staff compliant and documented. But it’s important to note that mandatory training already funded through Medicare or Medicaid will not be eligible.
- Infection prevention and control, including training, competency, and process documentation. This is the top F-Tag citation category for SNFs, making it the most common approved project type for grant funding.
- Policy and compliance infrastructure, such as documentation, policy acknowledgment, QAPI support, and technical assistance for compliance improvement programs.
How Does the CMP Application Process Work?
The first thing to note is that the CMP application process varies state-by-state and is always subject to change. With that in mind, here are the general steps to follow for the process:
- Identify the CMS-approved category your project is tied to.
- Determine who is the administering agency in your state. For example, it’s the Health and Human Services Commission (HHSC) in Texas. To find your state’s administering agency, refer to the CMS State Contacts for Civil Money Penalty Reinvestment document.
- Secure letters of support from each participating facility administrator.
- Complete the CMS-approved application for your state and submit it to your state agency. Submit a standard project proposal at least 90 days before the desired start date. Send in a multi-year project 120 days out.
Once submitted you can expect to hear back from CMS in one of three timeframes. If your proposal does not require any corrections, you can expect to hear from CMS in 30 days. If you require one round of corrections, expect 45 days. Two rounds of corrections, 60 days.
How Does Compliance Software Support CMP-Funded Compliance Projects?
Facilities that use the best healthcare compliance software, like MedTrainer, are positioned to show surveyors that they take resident care and wellness seriously. MedTrainer keeps your staff trained, your policies current, and your facility audit-ready, which signals to state survey agencies exactly the kind of commitment to resident outcomes they’re looking for. Agencies want to fund facilities where compliance isn’t an afterthought, but where staff actually know what to do, and residents are safer because of it.
MedTrainer streamlines everything an SNF needs to stay compliant year-round. Policy management, incident reporting, staff onboarding, safety plans, and real-time compliance dashboards are centralized right in the platform. In a 2023 poll, 99.8% of MedTrainer customers reported passing their audit or survey.
If your facility is exploring CMP grant opportunities, the groundwork starts with compliance. SNFs that can demonstrate a culture of compliance can better make that case. Understanding how the grant program works, what projects qualify, and how to document your outcomes puts you ahead of facilities that wait until a survey is coming to get organized.
Want to know if your facility qualifies?
We’ll walk you through your state’s window, the eligible project categories, and what a MedTrainer-backed application looks like — no commitment required.
