The Centers for Medicare & Medicaid Services (CMS) has updated its Frequently Asked Questions (FAQ) document for the Skilled Nursing Facility (SNF) Data Validation Process, providing additional clarification on submission deadlines, reporting timelines, and operational expectations under the SNF Quality Reporting Program (QRP).
The updated FAQs include new and revised guidance to address provider questions and support compliance with data validation requirements tied to Minimum Data Set (MDS)-based quality measures used in the SNF Value-Based Purchasing (VBP) Program and QRP.
Key updates in the revised FAQs include:
- Clarification that SNFs must submit all requested medical record documentation within 45 calendar days of the initial selection notification, with submissions due by 11:59 PM on the final day; if the deadline falls on a weekend or federal holiday, submissions are due by 11:59 PM on the next business day
- New guidance on the designation and role of points of contact (POCs) responsible for managing the data validation process and communications
- Confirmation that SNF validation summary reports (audit results) will be available in iQIES within approximately three months following the medical record submission deadline
- Additional detail on notification processes, including that facilities are selected on a rolling basis and notified through the MDS 3.0 Provider Preview Reports folder in iQIES
- Reinforcement of expectations that facilities routinely monitor iQIES to ensure timely awareness of selection notifications and submission requirements
CMS continues to emphasize that failure to meet submission deadlines may result in a finding of noncompliance and associated payment reductions. Facilities are encouraged to review the updated FAQs in full and ensure internal processes align with the clarified timelines and requirements.
Access the updated FAQ document here.
Compliance Perspective
Issue
CMS’s update to the SNF Data Validation Process FAQs clarifies key deadlines and reporting timelines that directly impact compliance under the SNF QRP. Facilities must be prepared to meet the 45-day submission requirement for requested documentation and understand the timing of validation results and CMS feedback. These clarifications reinforce the need for consistent internal processes, timely response to validation requests, and ongoing oversight to avoid noncompliance and potential payment reductions.
Discussion Points
- Review and update policies and procedures to reflect the clarified submission deadlines and reporting timelines outlined in the updated FAQs. Facilities should establish clear workflows for tracking selection notifications, coordinating documentation collection, and ensuring timely submission within the required 45-day window. Defined roles and accountability structures are critical to maintaining compliance, including designated responsibility for monitoring iQIES and managing validation timelines. Facilities may also benefit from working with their consultant to evaluate whether current processes effectively support deadline management, documentation accuracy, and alignment with CMS expectations.
- Provide education to staff responsible for MDS completion, medical record documentation, and compliance oversight to ensure they understand updated timelines, submission expectations, and documentation requirements under the Data Validation Process. Training should emphasize accuracy and consistency between MDS data and supporting medical records, as well as adherence to submission deadlines. Med-Net Academy offers the course Long-Term Care Survey Process, which reviews entrance requirements, the survey sample selection process, survey phases, mandatory and triggered facility tasks, and the purpose and scope of the Survey Pathways. This training supports staff readiness for regulatory oversight and strengthens understanding of compliance expectations.
- Conduct routine audits to assess the facility’s ability to meet CMS timelines and documentation requirements under the Data Validation Process. Audits should evaluate tracking systems for deadlines, completeness of submitted records, and consistency between MDS data and medical documentation. Incorporating mock reviews or focused audits can help identify gaps in advance of a validation request. Engaging an external consultant to perform independent assessments may further strengthen compliance efforts, validate internal processes, and support readiness for CMS review. Contact Med-Net Healthcare Consulting or info@mednetconcepts.com for more information.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*