The 2027 SNF PPS Final Rule finalized CMS’s proposal to revise the submission deadlines for both the SNF QRP and SNF VBP programs. The change applies to MDS assessment data and CDC NHSN data items.
The SNF QRP and SNF VBP publicly reported data is to provide consumers and their families with current quality of care information when researching facilities for their loved ones. CMS has identified that the time between when data on measures is submitted and when the data is publicly reported, which is nine months, may be too long to provide the most accurate and up to date information.
Why It Matters
Currently, there is about a nine-month lag between the end of the data collection period and when measures are publicly reported, which equals approximately 4.5 months tied to data submission. By shortening the submission window, CMS could reduce the overall reporting lag by up to three months. This would provide facilities and consumers with the most up to date and accurate information.
New Submission Deadlines
Beginning with the FY 2029 SNF QRP, SNFs must submit data — and make any necessary corrections to MDS assessment data and CDC NHSN data — no later than the 15th day of the second month after the end of each calendar quarter. If the 15th day of the second month falls on a Friday, weekend, or Federal holiday, the date is delayed until 11:59 p.m. EST on the next business day. The effective date will start January 1st, 2027.
Table 13 represents the MDS assessment data collection timeframes and data submission deadlines starting with FY 2029 SNF QRP.
Table 14 represents the NHSN data collection timeframes and submission deadlines starting with FY 2029 SNF QRP.
To align the revised SNF QRP submission deadline with the SNF VBP Program, CMS finalized an update to the “snapshot date” for the Review and Correction Process of the two MDS measures which include the DC Function and Falls with Major Injury (Long-Stay). The “snapshot date” is defined as the 15th day of the second month after the last day of the applicable baseline or performance period. For any of the MDS assessment data corrections in the SNF VBP Program’s quarterly confidential feedback reports, a SNF must make any corrections to the underlying data before the snapshot date and submit the corrections to iQIES.
How SNFs and NACs CAN PREPARE
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- Review MDS/NHSN data submission and validation processes
- Early detection of MDS dashes, errors, and inaccuracies through MDS audit reviews
- Utilize electronic software scrubbers to prevent erroneous information prior to submission
- Increase submission frequency more than once a week
- Ensure MDS team has backup staff in their absence
- Develop a report timeline and schedule to pull and review reports-MDS 3.0 QM Package Reports(weekly/monthly), SNF QRP reports (monthly), and SNF VBP and Five –Star Reporting reports (quarterly)
In conclusion, the finalized deadlines move SNF quality reporting and SNF value-based purchasing reporting closer to real-time data. SNFs will need to review, submit, and correct data more quickly. Facilities will need stronger internal timelines to avoid missed deadlines. Consumers and families will gain access to more timely facility quality data, supporting more informed decision-making related to care.