After months of anticipation, CMS has now provided clarity on the timing of the Skilled Nursing Facility Quality Reporting Program (SNF QRP) data validation audits. CMS issued an updated SNF QRP Data Validation FAQ in December 2025, clarifying timing and notification details and confirming that validation audits are now expected to begin in January 2026. The updated FAQ is available here: https://www.cms.gov/files/document/data-validation-process-frequently-asked-questions-12-17-2025.pdf
While this delay gives facilities additional time to prepare, it does not change how the validation process will work or how facilities will be notified once selections begin.
Facilities will be selected at random and notified individually through their iQIES MDS 3.0 Provider Preview Reports folder. Notifications are not sent by email and are not broadly announced. As a result, a facility can be selected without leadership realizing it unless someone is actively checking the system.
This makes having a simple, reliable monitoring process important, not because audits are underway today, but because missing a notification once rollout begins carries real consequences.
How facilities are notified
Facilities selected for validation will see a notification posted in the iQIES MDS 3.0 Provider Preview Reports folder. Notifications are clearly labeled as an Initial Selection Notification and, if needed, a Second Selection Notification. Once the notification is posted, the response clock begins whether or not it is immediately noticed.
Facilities have 45 calendar days from the posting date to submit the requested medical record documentation. Failure to respond within that window results in noncompliance under the SNF QRP, including a 2 percent reduction to the facility’s Annual Payment Update (APU) for the applicable program year.
What the validation audit involves
The SNF QRP data validation process is not a survey and does not affect survey outcomes. Instead, it evaluates the accuracy of MDS based quality measures used in the SNF QRP and SNF Value Based Purchasing programs.
If selected, a facility may be asked to submit medical records for up to 10 MDS assessments, following specific CMS instructions related to content, timeframes, formatting, and file naming. Documentation is submitted through a secure CMS portal, and facilities receive confirmation when records are received and accepted.
Importantly, there is no financial or regulatory penalty associated with audit findings themselves. The penalty applies only when a facility fails to participate or misses required submission deadlines.
A simple safeguard we recommend
To reduce risk without adding unnecessary burden, we recommend a brief weekly check of iQIES by a designated individual. This check typically takes less than a minute.
When no validation notification is present, saving a quick, dated screenshot provides simple documentation that the system was reviewed. This is not intended to create extra paperwork, but rather to demonstrate that notifications were not missed as CMS moves toward implementation.
In an environment where every new requirement feels burdensome, this is one of the simpler safeguards we’ve found to help prevent avoidable compliance problems.
This mirrors how many organizations already monitor critical portals and helps prevent leadership from being caught off guard by a time sensitive notice.
Why this matters now
Although validation audits have been delayed and are not yet underway, CMS has not withdrawn the SNF QRP data validation process. The primary risk is not audit outcomes. It is simply failing to recognize a posted notification and missing the required response timeframe once selections begin.
Leadership should ensure responsibility for checking iQIES is clearly assigned, the check is built into existing workflows, screenshots are retained to document when no notification is present, and iQIES Points of Contact remain current and accurate.
How Polaris Group can help
Polaris Group is prepared to assist organizations if and when a SNF QRP validation audit notification is received. We can support record selection, documentation review, submission readiness, and communication throughout the validation process.
Beyond audit response, Polaris works proactively with organizations to help manage quality programs across SNF QRP, Five Star, and VBP. Strengthening monitoring routines and internal processes now helps reduce last minute risk and allows teams to stay focused on resident care.
A practical takeaway
Think of the SNF QRP validation audit like a fire drill. It may not affect you immediately, but preparedness matters. A simple, weekly check, clearly assigned and minimally documented, can make the difference between a smooth response and an avoidable compliance headache.
