Everything to Know About CMS Requirements for Director of Nursing Roles
The Director of Nursing (DON) plays a pivotal role in the day-to-day operations of long-term care and skilled nursing facilities. As the top clinical leader, the DON oversees nursing staff, patient care, and regulatory adherence. But to hold this role in a Medicare- or Medicaid-certified facility, certain qualifications must be met—and those are governed by the CMS requirements for Director of Nursing.
Meeting these requirements is about more than checking boxes. It’s about ensuring the safety and well-being of residents, staying in good standing with regulatory bodies, and running a compliant, high-functioning care environment. Whether you’re hiring for this position or working toward it yourself, understanding what CMS expects is the first step toward success.
Why Meeting CMS Requirements Matters for Your Director of Nursing and Your Facility
Directors of Nursing are at the heart of clinical leadership, and their qualifications directly influence patient outcomes, staffing efficacy, and regulatory standing. A DON who doesn’t meet proper requirements can put an entire facility at risk for citations, funding cuts, or even loss of accreditation. In addition, meeting these standards ensures that your nursing leadership has the education and experience necessary to make informed decisions, lead teams effectively, and support organizational success.
What Are the CMS Requirements for Director of Nursing?
According to CMS requirements for Director of Nursing roles, you must be a currently licensed registered nurse (RN) in the state in which you practice. This is a foundational requirement for anyone assuming the role of DON in a Medicare-certified hospital.
The Joint Commission (TJC) builds upon CMS regulations and outlines further qualifications for Nurse Executives in its Nursing Standards Chapter, Standard NR.01.02.01. These requirements include:
- The DON must be a licensed RN in their state of practice.
- The DON must have a postgraduate degree in nursing or a related field, or the knowledge and skills equivalent to an advanced degree.
- If the hospital requires leadership peers (e.g., department heads, executives) to have an advanced degree or professional certification, the DON should possess similar qualifications.
These standards aim to ensure that individuals in leadership roles have the education and capabilities to meet modern healthcare demands. A DON who fulfills both CMS and TJC criteria demonstrates the strategic and clinical proficiency required to lead in today’s complex care environment.
The Director of Nursing’s Role in Maintaining CMS Compliance
The Director of Nursing must meet regulatory qualifications while also helping to ensure the entire nursing department remains CMS-compliant. From infection prevention and medication management to patient assessments and quality assurance, DONs are involved in nearly every aspect of CMS survey preparedness. A qualified DON understands the nuances of CMS guidelines and proactively addresses areas of risk.
This role includes:
- Ensuring accurate and timely nursing documentation
- Training staff on CMS-mandated policies
- Participating in quality improvement programs
- Collaborating with medical staff on care delivery models
When a DON meets both educational and licensing requirements, they are better equipped to drive initiatives that meet regulatory expectations while improving patient outcomes.
Common Challenges in Meeting CMS Requirements
Despite their importance, CMS requirements for Directors of Nursing can be difficult to meet consistently. Here are a few common challenges facilities face:
High Turnover and Burnout
The DON role is demanding. It’s not uncommon for facilities to face high turnover, which can jeopardize compliance—especially if temporary or interim hires don’t meet CMS criteria. Without full-time leadership, care quality and regulatory performance often decline.
Inconsistent State Guidance
CMS provides federal requirements, but state surveyors often interpret and enforce them differently. That can create confusion, particularly in areas where regulations lack specificity—like what constitutes “sufficient experience.”
Lack of Onboarding Support
Even the most qualified and capable DON may struggle without proper orientation and tools. Facilities that don’t provide structured onboarding, clear policies, or CMS-aligned training risk falling out of compliance despite having the right person in place.
Documentation and Policy Gaps
Many compliance issues stem not from clinical care, but from documentation or procedural missteps. If policies are outdated or inconsistently applied, even the best DON can’t maintain compliance effectively.
How MCN Solutions Supports Director of Nursing Compliance
At MCN Solutions, we help facilities like yours ensure that Directors of Nursing not only meet CMS qualifications but thrive in the role with our streamlined policy management software and beyond. Our healthcare policy management services are designed to simplify compliance, reduce risk, and equip your team for excellence.
We offer:
- CMS-compliant policy and procedure manuals customized for your state and facility type
- Regulatory updates so your leadership team is always aligned with the latest CMS guidelines
- Training and onboarding materials to help new DONs step confidently into the role
- Survey preparedness tools to guide your team through mock audits and quality reviews
Our goal is to take the guesswork out of compliance so your DON can focus on what matters most—delivering exceptional care.
Stay Compliant with Confidence
Understanding and meeting the CMS requirements for Director of Nursing is essential for any certified facility. With the right person in place—backed by the right tools—your organization is better positioned to provide high-quality care, pass inspections, and build trust with families.
If you’re unsure whether your policies, training systems, or leadership qualifications align with CMS standards, we’re here to help. Contact us here and we can get started today!