CMS has announced the implementation of a skilled nursing facility (SNF) validation program. The validation program is an audit-based program that will assess the accuracy of Minimum Data Set (MDS)-based quality measures used in the SNF Quality Reporting Program (QRP) and the SNF Value-Based Purchasing (VBP) Program. The program is scheduled to begin in fall 2025 and will be conducted by the program contractor of Healthcare Management Solutions, LLC (HMS).
Beginning this fall (fiscal year (FY) 2026), a random selection of up to 1,500 SNFs will be selected to submit documentation for validation of up to 10 MDS assessment records. SNFs are eligible for selection if they submitted at least one MDS assessment in the previous calendar year and have submitted at least one MDS assessment record in the current FY. A SNF can only be selected once within a fiscal year.
SNFs will be notified of their selection for participation in audits through their Internet Quality Improvement and Evaluation System (iQIES) MDS 3.0 Provider Preview Reports folder. The audit notification will provide a list of residents with detailed data requests for resident medical records associated with the MDS assessments under review, instructions for submission of information, and the contact information of the contractor completing the audit.
Current measures to be validated include percentage of residents with falls with major injuries, pressure ulcer/pressure injury rate, Drug Regimen Review with follow-up, Discharge Function scores, Discharge to Community, and Transfer of Health Information.
At the audit’s conclusion, SNFs will receive a Summary Audit Scoring Report within three months via iQIES that will contain their audit results for each measure and MDS item that will include detailed results from each sampled resident assessment and medical record reviewed. These reports are for informational use only, as SNFs will not be penalized for their audit results.
SNFs that fail to comply with the program requirements due to failure to respond to their notification of selection will receive a Summary Audit Report that will include a notification that they were non-compliant with the Validation Program and will also receive a non-compliance notification letter from their Medicare Administrative Contractor (MAC). Non-compliant SNFs will be subject to a 2% reduction of their Annual Payment Update (APU) for the subsequent fiscal year.
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