Hopefully, you (and your Minimum Data Set (MDS) Coordinator or Resident Nurse Assessment Coordinator (RNAC)) are aware of the importance of checking the Validation Reports after submitting MDS assessments. This has always been the expectation and best practice to find any errors in a timely manner, make corrections, and ensure that MDS submissions are accurate and accepted.
If you are in the habit of checking your Validation Reports in the Internet Quality Improvement and Evaluation System (iQIES) system regularly, you are most likely not going to be impacted by this new initiative rolled out by the Centers for Medicare & Medicaid Services (CMS) in June 2025 that is set to begin in the fall of 2025. The Skilled Nursing Facility (SNF) Validation Program has been established to assess the accuracy of MDS-based quality measures used in the SNF Value-Based Purchasing (VBP) program. CMS has prepared an eight-page document entitled: SNF Validation Program FAQs.
Here are some highlights:
What is the SNF Validation Program?
The SNF validation program is an audit-based program established to assess the accuracy of MDS-based quality measures used in the SNF VBP and Quality Reporting Programs (QRPs).
Who is performing the validation audits?
CMS has hired an external contractor to perform the audits Healthcare Management Solutions, LLC. (HMS).
How will SNFs be selected for the audit?
SNFs will be randomly selected for audit and will be notified through their iQIES MDS 3.0 Provider Preview Reports folder. The audit notification will contain instructions for documentation submission, the list of sampled residents for which medical charts are being requested, and contact information for the contractor conducting the audit.
What will be required to pass the audit?
SNFs are required to submit requested medical chart documentation to support validation of ten (10 ) MDS assessment records. Any selected SNF that fails to submit the requested medical chart documentation within 45 calendar days of the audit notification will be considered noncompliant.
What are the consequences of noncompliance in the validation audit?
For the FY2025 performance year/FY2027 program year, noncompliance may result in a 2% reduction of a SNF’s Annual Payment Update (APU) for the FY2027 SNF QRP program year in accordance with Section 1888(e)(6)(A) of the Act.
What are the Takeaways from the SNF Validation Program?
- Print off the SNF Validation Program FAQs and review!
- Be on the lookout in your iQIES for any notifications.
- Submit documents within 45 days of receipt of the notification.
If you have any questions, please contact Kay Hashagen, PT, MBA, RAC-CT at khashagen@lw-consult.com or (410) 777- 5999.
