• Beginning with residents admitted on Oct 1, 2029, CMS is expanding QRP Reporting and MDS submissions to ALL skilled patients regardless of payer. Failure to transmit may result in a 2% QRP Penalty.

D. Value Based Purchasing (VBP)

• CMS finalized the performance thresholds for FY2027 VBP Performance
• The Achievement Threshold for the DC Function Measure is 42.85%, and the Benchmark is 84.52%

E. Case Mix Creep

• CMS summarized the comments it received on “case mix creep.” 
• Case Mix Creep refers to an increase in MDS coding without a corresponding change in case mix.
• CMS will use this feedback to help reshape future PDPM policy changes, but is not making any PDPM changes at this time.

We will be hosting a webinar in September to review these updates in more detail.

Stay tuned for an announcement.

SNF PPS FY2027 Final Rule: https://public-inspection.federalregister.gov/2026-15562.pdf

If you have any questions or need additional information, please email us at:

• Medicarequestions@enhancetherapies.com

SNF VBP Performance Reports are now available for download from iQIES.

These reports indicate a SNF’s FY2025 performance in the 8 VBP measures that will determine its FY2027 Medicare A payment.

The 8 SNF VBP Measures are:

• 30-Day Hospital Readmission Measure (SNFRM)
• Healthcare-Associated Infections Requiring Hospitalization (SNFHAI)
• Successful Discharge to Community (DTC)
• # of Hospitalizations per 1,000 Long Stay Resident Days
• Total Nursing Staff Turnover
• Total Nurse Hours per Resident Day
• Discharge Function Score
• Falls with Major Injury (Long-Stay)

Measure results will be used to calculate your Med A payment multiplier that will take effect on October 1, 2026.

Please note, that while the current reports indicate measure performance, they do not yet indicate final scores or payment multipliers.

The final Performance Score Report with Med A payment multipliers will be released in August; however, these reports can still give you important insight into how you will fare.

Tab 2: Overview of Measure Results

Column C indicates your SNF’s performance

Column D tells you how it compares nationally

VBP points are assigned based on national ranking; therefore, the better you perform relative to the national benchmark, the higher your points and the higher your payment multiplier.

We suggest you perform a QAPI on any areas that are low (especially the DC Function Measure), as these measures will continue to affect Medicare A payment in the coming years.

The current ABN Form, CMS R-131, was originally set to expire on Jan 31, 2026, but was delayed since the new ABN form was not yet approved.

(see expiration date on bottom of current ABN form)

Special Focus Facilities (SFFs) are facilities designated by the State because they are found to have more deficiencies than most nursing homes. These facilities must have on-site inspections no less than every six months, and enforcement actions can be imposed (e.g., civil monetary penalties, denial of Medicare payment, etc.) until the nursing home either graduates from the SFF program or is terminated from Medicare and/or Medicaid.

On January 28, 2026, CMS released QSO-23-01-NH which implemented a major change to SFF selection.

In this memo, CMS revised the focus for SFF selection to emphasize the prevalence of FALLS.

CMS recommends that if the State is considering two facilities for SFF selection with a similar compliance history, they should select the one with the higher prevalence of falls.

For the last three years, CMS has instructed States to select SFF Facilities based on Staffing Levels, but now CMS is shifting the focus to falls!

This is due to a recently released OIG report that highlighted the seriousness of falls in nursing homes.

The OIG found that Medicare-enrolled nursing home residents experienced more than 42,000 falls with major injury over a one-year period. These falls reduced residents’ quality of life and were costly for the Medicare program.

In addition, the OIG found that falls are significantly underreported, thus making CARE Compare an unreliable tool. The OIG found that 43% of Falls with Major Injury were not reported on the MDS!

To address this issue, CMS released a Technical Specification Report last November recommending the incorporation of claims data into the Falls with Major Injury QRP measure to improve accuracy; however, they have not yet proceeded with this.

As a reminder, Falls with Major Injury is also a Medicare VBP (Value-Based Purchasing) Measure and contributes to Five-Star Rating.

A nursing home’s falls data is accessible in iQIES in the MDS 3.0 Facility-Level Quality Measure report.

It is important that MDS coordinators pull these reports monthly and share them with the Rehabilitation Department.

It is also critical to identify fall risks and mitigate them before they occur.

Some risks of falls include: decreased balance, inappropriate assistive device, poor footwear, contractures, poor transfers, inability to make needs known, poor positioning, and generalized weakness.

The Rehabilitation Department plays a key role in implementing strategies to minimize falls and improve patient quality of life!

QSO-23-01-NH: https://www.cms.gov/files/document/qso-23-01-nh-revised-2026-01-28.pdf

OIG Report: https://oig.hhs.gov/documents/sar/11445/Fall_2025_SAR–508.pdf

Falls TSP Report: https://www.cms.gov/files/document/fmi-technicalspecificationsreport-nh.pdf

If you have questions, or need additional information, please email us at:

Medicarequestions@enhancetherapies.com