The Centers for Medicare & Medicaid Services (CMS) has announced that the Skilled Nursing Facility (SNF) Data Validation Process for the SNF Value-Based Purchasing (VBP) and SNF Quality Reporting Program (QRP) will begin in January 2026. This follows CMS’s earlier announcement that implementation was suspended indefinitely and establishes January 2026 as the start date.
CMS will begin issuing selection notifications to SNFs in mid-January 2026, with additional notifications released on a rolling basis throughout the year. Selection notifications will be communicated exclusively through the Internet Quality Improvement and Evaluation System (iQIES).
Selected SNFs will receive their notification in the iQIES MDS 3.0 Provider Preview Reports folder. The initial notice will be titled “Skilled Nursing Facility Data Validation Process – Initial Selection Notification.” CMS has stated that no notifications will be sent outside of iQIES. SNFs are therefore encouraged to begin reviewing their iQIES folders at least weekly starting in January 2026.
SNFs selected for the data validation process are required to submit medical chart documentation to support validation of up to 10 MDS assessment records. The notification letter will include detailed instructions regarding the specific records requested, the documentation required, and the secure submission process.
Failure to submit the requested medical record documentation within 45 calendar days of the selection notification will result in a finding of noncompliance. Noncompliant SNFs will incur a 2 percent reduction to their Annual Payment Update for the applicable fiscal year. CMS has clarified that for the FY 2025 data validation cycle, penalties are applied only for failure to submit requested documentation within the required timeframe, not based on validation findings.
SNFs that believe a noncompliance determination has been made in error may request reconsideration through the CMS reconsideration process, in accordance with applicable program requirements and timelines.
Additional information is available on CMS’s data validation process webpage, including training materials and the recently updated Frequently Asked Questions (FAQs).
Compliance Perspective
Issue
CMS’s announcement that the SNF Data Validation Process for the VBP and QRP will start in January 2026 requires facilities to ensure compliance with MDS documentation submission requirements. Selected SNFs will be required to respond to data validation requests issued through iQIES and submit complete documentation within 45 calendar days to avoid a finding of noncompliance and associated payment reductions. Because selection occurs on a rolling basis and notifications are issued exclusively through iQIES, facilities must maintain ongoing readiness, clearly defined internal processes, and effective oversight to ensure timely identification of notices and accurate submission of required records.
Discussion Points
- Review and update policies and procedures to ensure they address the SNF Data Validation Process requirements, including routine monitoring of iQIES folders, assignment of responsibility for responding to validation notices, and standardized workflows for compiling and submitting requested medical record documentation. Policies should clearly define roles related to MDS oversight, medical record management, and submission timelines. Facilities may benefit from working with their consultant to evaluate whether existing procedures are sufficient to support timely responses and to identify opportunities to strengthen documentation readiness before a validation notice is received.
- Provide targeted education to staff responsible for MDS completion, medical record documentation, and compliance oversight to ensure they understand the data validation process, submission timelines, and documentation expectations. Training should emphasize accuracy and consistency between MDS data and supporting medical records, as well as the consequences of missing the 45-day submission deadline. Med-Net Academy offers the course Long-Term Care Survey Process, which covers entrance requirements, sample selection, survey phases, mandatory and triggered facility tasks, and the purpose and scope of the Survey Pathways. The course provides practical guidance to support staff readiness for regulatory oversight and compliance activities.
- Conduct periodic audits to assess readiness for the SNF Data Validation Process, including reviews of MDS accuracy, supporting medical record documentation, and tracking processes for regulatory notices and deadlines. Audits can help identify documentation gaps, workflow inefficiencies, or communication breakdowns that could delay submission if a facility is selected. Working with an external reviewer or consultant on focused or mock audits can help identify compliance gaps and ensure internal practices meet CMS expectations before a formal data validation request.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*