The Minimum Data Set (MDS) plays a vital role in driving resident care through the resident-centered care plan process, regulatory compliance, Medicare and Medicaid reimbursement, quality outcomes, and reporting programs. MDS data accuracy has been under increased scrutiny from surveyors on the regulatory side and Medicare Administrative Contractors (MACs), Recovery Audit Contractors (RACs) and other contract entities focused on accuracy as it relates to Medicare and Medicaid reimbursement. With this in mind, CMS has recently announced the implementation of an MDS validation process to assess the accuracy of data as it relates to the SNF quality reporting (SNF QRP) and Value Based Purchasing (VBP) programs. Understanding the ins and outs of this process is key to avoiding penalties related to non-compliance.
What is the SNF Validation Program?
The SNF Validation Program is an audit-driven initiative which focuses on assessing the accuracy of the MDS data used in calculating the quality measures. The goal of the program is to ensure the data used for the quality measures is accurate, reliable and complies with regulations.
How the validation process works:
Beginning this fall (FY2026) CMS will select a random sample of up to 1,500 SNFs to participate in the program each fiscal year—requiring selected SNFs to provide documentation for validation for up to 10 residents. Any SNF who submitted at least one MDS assessment through IQIES during both the preceding fiscal year and current calendar year may be eligible for selection, but a facility may only be selected for review once per fiscal year.
Notification of selection:
SNFs will be notified of their selection through their IQIES provider preview reports folder. Most facilities check this folder regularly to access their Five Star Provider Rating Reports, and reviewing this folder will be essential going forward. The notification letter will provide the facility with the following information:
- Instructions for submitting the requested documentation
- List of the sample residents for which the medical record documentation is requested with detailed data requests for medical records associated with MDS assessments under review
- Contact information of the contractor completing the audit
SNFs must use the link contained within the notification to designate and submit Point of Contacts to receive audit-related email notifications, including file uploads, documentation submissions, and any issues with medical records. If needed, the contact information can be revised and updated via the provided link.
Submission Requirements:
Facilities selected for audit must respond to the notification by submitting the requested documentation for each resident identified in the sample list within 45 days of the date of the notice. The documentation must be submitted in PDF format through the secure portal. Facility POCs will receive an email notification (1) when the documentation is successfully uploaded and (2) once the uploaded documents have been verified. Failure to submit the requested documentation timely will result in the facility being found non-compliant.
Validation Audit Results and Penalties:
SNFs will receive an audit summary report through IQIES approximately 3 months after the submission deadline. The report will contain the SNF’s audit results for each measure and MDS item, including detailed results from each sampled assessment and medical chart audited. The good news for the SNF is that the reports are for informational purposes only and no penalties will be applied based on identified errors or error rates. Facilities that are found to be non-compliant due to the failure to respond to the notification of selection and do not submit records for review timely will be subject to a 2% reduction in the annual payment update for the subsequent fiscal year.
Strategies for Success:
- Be alert and responsive: Recognize your facility may be selected for validation at any time and check IQIES for a notice on a weekly basis to allow for a complete and timely response
- Validate the presence of medical record documentation to support the coding of data used in calculating the SNF quality measures including:
- Section GG – Functional Assessment
- Pressure ulcers
- Falls and fall related injuries
- Completion of resident interviews (BIMS, Pain, PHQ2-9, social isolation, health literacy,
- Completion of drug regimen review process and provision of reconciled medication list to residents and subsequent provider
- Provide ongoing education and staff training for the IDT MDS staff on coding and supportive documentation guidelines.
- Ensure documentation exists to support the submission of complete and accurate MDS data.
- Review validation reports for errors related to incomplete submissions. Utilize the Review and Correct process to make corrections when supported by the documentation.
- Stay informed of updates and changes to the Quality Measure and documentation requirements
- Incorporate Quality Measures and MDS verification processes into the facility’s QAPI program.
By preparing for the process and being alert to the audit notifications, the facility can be a step ahead of the SNF Validation Program, with positive strides toward validation success. Contact Proactive LTC Consulting for more information on support services to ensure MDS accuracy and for improving your facility QM, QRP and VBP outcomes.
Written By:
Christine Twombly, RN-BC, RAC-MT, RAC-MTA, HCRM, CHC
Senior Consultant
Proactive LTC Consulting
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