The Centers for Medicare & Medicaid Services (CMS) has released a detailed Frequently Asked Questions (FAQ) document to assist skilled nursing facilities (SNFs) in understanding and complying with the new Data Validation Process. The FAQs provide essential guidance ahead of the process launch in fall 2025, which will impact the FY 2027 Skilled Nursing Facility Quality Reporting Program (QRP).
CMS developed the FAQ to address common questions from providers about the requirements, procedures, and timelines associated with the Data Validation Process. According to CMS, this initiative is designed to ensure the accuracy of quality data reported by SNFs through the Minimum Data Set (MDS). This data supports programs that measure and improve the quality of care, including the QRP and the Value-Based Purchasing (VBP) Program.
Topics covered in the FAQ include:
- Who is subject to the validation process and how facilities are selected
- How SNFs will be notified of their selection and how to access these notifications
- The types of medical record documentation SNFs must submit to demonstrate compliance
- Required submission formats, timelines, and naming conventions for documentation
- Security measures protecting submitted documentation
- How CMS will communicate validation results and findings
- Consequences for noncompliance and available appeal procedures
- Contact information for assistance and support throughout the process
CMS has also made additional training materials and resources available alongside the FAQs to help SNFs prepare for their participation. The FAQ document and related resources are available here.
Compliance Perspective
Issue
CMS has published a detailed FAQ document to support SNFs as they prepare for the new Data Validation Process starting in fall 2025. This federally mandated process requires randomly selected SNFs to submit medical record documentation to validate MDS quality data used in the QRP and the VBP program. Facilities must understand the requirements, timelines, and compliance obligations outlined in the FAQs to avoid potential penalties, including a 2 percent reduction in Medicare reimbursement for noncompliance.
Discussion Points
- Review and update policies and procedures to incorporate CMS’s Data Validation Process requirements as detailed in the FAQs. Develop clear processes to promptly identify validation requests, collect and submit required medical documentation, and manage communications. Facilities may benefit from collaborating with external consultants who specialize in regulatory compliance and documentation management to ensure these policies are comprehensive and aligned with CMS expectations. Ensure roles and responsibilities are clearly assigned to meet submission deadlines and maintain compliance.
- Provide comprehensive training to relevant staff on the Data Validation Process, including documentation standards, submission deadlines, and potential penalties for noncompliance. Med-Net Academy offers the course Understanding and Using the Medicare Triple Check Process, which is designed to help staff improve billing accuracy for skilled services, avoid false claims, minimize denials or adjustments, ensure residents receive the benefits they’re entitled to, and better align clinical documentation with financial data.
- Conduct audits or mock validation exercises to assess readiness for CMS’s data validation requests. These audits can verify that medical record documentation aligns with MDS data and meets CMS submission requirements. An external review—such as a focused audit or mock assessment—can help identify potential gaps and strengthen submission readiness. Use audit findings to address gaps, enhance processes, and reinforce compliance practices proactively.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*