Creator: Alicia Cantinieri
SNF QRP: Reporting Today to Protect Tomorrow's Medicare Payments
Alicia’s monthly report focuses on the Skilled Nursing Facility Quality Reporting Program, giving a tutorial on its purpose and what providers must know about changes to it in the 2027 SNF PPS.
Understanding the SNF QRP
The Skilled Nursing Facility Quality Reporting Program (SNF QRP) is a CMS pay-for-reporting program designed to measure and publicly report the quality of care provided during skilled nursing stays. CMS calculates QRP measures using information from the Minimum Data Set (MDS), Medicare claims, and other required sources. Measures address areas such as functional outcomes, falls with major injury, pressure injuries, healthcare-associated infections, and successful discharge to the community.
SNFs must submit complete and accurate data by CMS-established deadlines. Failure to meet the applicable reporting requirements may result in a two-percentage-point reduction in the facility's Annual Payment Update (APU). CMS also provides confidential performance reports and Provider Preview Reports through iQIES, allowing facilities to review their results before measures are publicly reported on Medicare Care Compare. Consequently, QRP can affect both Medicare reimbursement and the public's perception of a facility's quality.
Current Reporting Requirements
SNFs currently must submit 100 percent of the required data for two healthcare personnel measures reported through the CDC's National Healthcare Safety Network (NHSN):
• COVID-19 Vaccination Coverage Among Healthcare Personnel
• Influenza Vaccination Coverage Among Healthcare Personnel
In addition, at least 90 percent of applicable MDS assessments must contain 100 percent of the required QRP and Standardized Patient Assessment Data Element (SPADE) information. Currently, this requirement applies to applicable Traditional Medicare fee-for-service skilled stays. The data are reported through PPS 5-Day and Part A PPS Discharge assessments submitted to iQIES.
A non-informative dash generally prevents an assessment from counting as complete, even when the dash is an available MDS response. Valid skip patterns and item-specific exceptions are handled according to CMS specifications. Although a facility may remain compliant with up to 10 percent of applicable assessments incomplete, the operational goal should be 100 percent completion.
Financial Consequences of Noncompliance
The QRP penalty reduces a facility's APU by two percentage points for the applicable federal fiscal year. It does not result in claim denials or a direct 2 percent deduction from every Medicare payment. Instead, CMS calculates the facility's Medicare Part A PPS rates using the reduced annual update, lowering payments throughout the fiscal year.
For Fiscal Year (FY) 2027, CMS finalized a 2.4 percent SNF PPS payment update. A facility subject to the QRP penalty would receive only a 0.4 percent update. The penalty is based on whether the required data were reported—not on the facility's performance on the quality measures.
For the FY 2027 APU determination, MDS quality-measure and SPADE data came from calendar year 2025 and were submitted by the applicable quarterly deadlines, with the final quarter due May 18, 2026. Facilities subject to the penalty are notified through iQIES and their Medicare Administrative Contractor. Reconsideration is available, but CMS grants relief only under limited circumstances.
What Is Changing?
The FY 2027 SNF PPS Final Rule makes several important QRP changes:
• COVID-19 measures: Beginning with the FY 2028 SNF QRP, CMS will remove the healthcare personnel and resident COVID-19 vaccination measures.
• Shorter submission period: Beginning with the FY 2029 SNF QRP, the current 4.5-month submission and correction period will be shortened to approximately 45 days after the end of each quarter.
• Expanded MDS reporting: Beginning with the FY 2031 SNF QRP, facilities must submit MDS data for all residents receiving covered skilled care, regardless of payer. This will include applicable residents covered by Medicare Advantage, Medicaid, or private insurance.
CMS intends to modify one MDS item and add three items to identify skilled services, skilled-stay dates, and primary payer information. Although many facilities already complete assessments for non-Medicare residents, these assessments may not currently be submitted to iQIES for QRP purposes. Expanding the reporting population will increase the number of assessments included in the 90 percent completion calculation and may increase the facility's risk of noncompliance.
Preparing Now
Facilities should begin preparing before these requirements take effect. Data threshold reports should be reviewed more frequently than quarterly, and assessments should be audited for completeness and accuracy before initial submission. Organizations must also determine how non-Medicare skilled residents will be identified, assessed, tracked, and reported.
With shorter correction periods and a broader reporting population ahead, proactive monitoring today will be essential to protecting both tomorrow's quality results and Medicare reimbursement.
Alicia Cantinieri, MBA, BSN, RN, CHC, RAC-MT, RAC-CTA, DNS-CT, QCP, is the managing director, clinical reimbursement and regulatory compliance, Zimmet Healthcare Services Group.
Questions or comments on the article? Contact Patrick Connole at pconnole@parkplacelive.com.
