In the FY 2024 Final Rule, CMS introduced the Skilled Nursing Facility (SNF) Validation Program.
In the FY 2024 Final Rule, CMS introduced the Skilled Nursing Facility (SNF) Validation Program. This initiative is designed to verify the accuracy of MDS-based quality measures used in the SNF Quality Reporting Program (QRP) and the SNF Value-Based Purchasing (VBP) Program.
Beginning Fall 2025, CMS will launch nationwide audits of SNFs. These reviews will not assess quality of care directly but will check whether the data facilities submit through the MDS is accurate and supported by resident medical records.
How the Audit Works
- Selection: Facilities are randomly chosen from those that submitted MDS records in both the prior and current fiscal year.
- Notification: Audit notices appear in the facility’s iQIES Provider Folder (not by email or mail).
- Response Window: Facilities have 45 calendar days to submit medical records for 10 sampled MDS assessments.
- Submission: Records must be uploaded securely in PDF format according to CMS guidelines.
Why This Matters
- Facilities that do not respond within 45 days will be deemed noncompliant.
- Noncompliance results in a 2% reduction to Medicare payments through the Annual Payment Update (APU). This reduction applies to all Medicare Part A payments for the following fiscal year.
- Audit results themselves do not create penalties—the risk comes from failing to respond on time.
What Facilities Should Do Now
- Assign a staff member to monitor the iQIES Provider Folder weekly.
- Be prepared to gather and upload records quickly if selected.
- Educate leadership and care teams on the new requirements so everyone understands the process.
- Review the official CMS SNF QRP Validation Program FAQ for detailed guidance.
Bottom Line
The new validation audits are all about accuracy and accountability. With proactive preparation, facilities can avoid penalties and demonstrate confidence in their quality data.
Connect with Polaris Group today to protect your revenue and strengthen compliance before audits begin.
