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Ask Amanda: Understanding the New CMS SNF Data Validation Process

Amanda Earp
Amanda Earp
October 9, 2025
November 13, 2025
Amanda Earp
Polaris Group
November 13, 2025
Summary

CMS has officially begun conducting SNF Data Validation Audits to confirm that documentation supports the quality-measure data.

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CMS has officially begun conducting Skilled Nursing Facility (SNF) Data Validation Audits to confirm that documentation supports the quality-measure data submitted through the MDS. These reviews are now underway for the FY2027 SNF Quality Reporting Program (QRP) year.

Facilities are being randomly selected, and one detail is critical: notifications appear only in iQIES. CMS does not send audit selections through email or mail. If the notice is missed, the 45-day response window can be lost before a facility even knows it was selected.

What’s Happening Now

Check iQIES Weekly

Navigate to:
Reports → My Reports → MDS 3.0 Provider Preview Reports and look for:
“Skilled Nursing Facility Data Validation Process – Initial Selection Notification.”

A second “Selection Notification” may follow later.
This is the only official notice. There are no emails or mailed letters.

Once Selected

Facilities have 45 calendar days from the iQIES posting date to submit up to ten resident medical record bundles in PDF format.
Requirements include:

  • One PDF per resident
  • Naming format: CCN_ValidationID.pdf
  • Documentation must match the requested date range
  • Exclude face sheets and Social Security numbers

Results & Penalties

Audit results are informational. However, failure to submit documentation on time can result in a two percent Annual Payment Update (APU) reduction under the SNF QRP for FY2027.

Reconsideration requests are generally due within 30 days of CMS’s noncompliance notice.

Official resource:
CMS SNF Data Validation Process: FAQs (August 2025)

Why the Audit Matters: A Quick Refresher on SNF VBP and SNF QRP

SNF Quality Reporting Program (QRP) – Pay for Reporting

The QRP, mandated by the IMPACT Act of 2014, requires SNFs to submit specific quality data each year. Required measures are published annually by October 1.

The IMPACT Act requires standardized, interoperable assessment data and reporting across quality, resource use, and other domains. The goal is to support improved beneficiary outcomes through better care coordination, shared decision-making, and enhanced discharge planning.

SNF Value-Based Purchasing (VBP) – Pay for Performance

CMS awards incentive payments to SNFs through the VBP Program to encourage improved care.
For FY2026, performance will be evaluated based on four measures:

  • All-cause hospital readmissions
  • Healthcare-associated infections resulting in hospitalization
  • Staffing hours
  • Staffing turnover

Bottom Line

CMS’s SNF Data Validation Audits are active now. Notices live exclusively in iQIES, and compliance depends on timely review and accurate, complete documentation.

Polaris can support your team with proactive mock audits, data accuracy reviews, and targeted training that reduces your risk before you are selected.

Have a topic or question you’d like featured in Ask Amanda? We’d love to hear from you and are here to support your success.

CMS has officially begun conducting Skilled Nursing Facility (SNF) Data Validation Audits to confirm that documentation supports the quality-measure data submitted through the MDS. These reviews are now underway for the FY2027 SNF Quality Reporting Program (QRP) year.

Facilities are being randomly selected, and one detail is critical: notifications appear only in iQIES. CMS does not send audit selections through email or mail. If the notice is missed, the 45-day response window can be lost before a facility even knows it was selected.

What’s Happening Now

Check iQIES Weekly

Navigate to:
Reports → My Reports → MDS 3.0 Provider Preview Reports and look for:
“Skilled Nursing Facility Data Validation Process – Initial Selection Notification.”

A second “Selection Notification” may follow later.
This is the only official notice. There are no emails or mailed letters.

Once Selected

Facilities have 45 calendar days from the iQIES posting date to submit up to ten resident medical record bundles in PDF format.
Requirements include:

  • One PDF per resident
  • Naming format: CCN_ValidationID.pdf
  • Documentation must match the requested date range
  • Exclude face sheets and Social Security numbers

Results & Penalties

Audit results are informational. However, failure to submit documentation on time can result in a two percent Annual Payment Update (APU) reduction under the SNF QRP for FY2027.

Reconsideration requests are generally due within 30 days of CMS’s noncompliance notice.

Official resource:
CMS SNF Data Validation Process: FAQs (August 2025)

Why the Audit Matters: A Quick Refresher on SNF VBP and SNF QRP

SNF Quality Reporting Program (QRP) – Pay for Reporting

The QRP, mandated by the IMPACT Act of 2014, requires SNFs to submit specific quality data each year. Required measures are published annually by October 1.

The IMPACT Act requires standardized, interoperable assessment data and reporting across quality, resource use, and other domains. The goal is to support improved beneficiary outcomes through better care coordination, shared decision-making, and enhanced discharge planning.

SNF Value-Based Purchasing (VBP) – Pay for Performance

CMS awards incentive payments to SNFs through the VBP Program to encourage improved care.
For FY2026, performance will be evaluated based on four measures:

  • All-cause hospital readmissions
  • Healthcare-associated infections resulting in hospitalization
  • Staffing hours
  • Staffing turnover

Bottom Line

CMS’s SNF Data Validation Audits are active now. Notices live exclusively in iQIES, and compliance depends on timely review and accurate, complete documentation.

Polaris can support your team with proactive mock audits, data accuracy reviews, and targeted training that reduces your risk before you are selected.

Have a topic or question you’d like featured in Ask Amanda? We’d love to hear from you and are here to support your success.

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