IMPORTANT CMS UPDATE: 08/10/2026 – FIRST MANDATORY NATIONWIDE BUNDLING MODEL

FIRST MANDATORY NATIONWIDE BUNDLING MODEL: CJR-X FINALIZED

On July 31, 2027, CMS released the FY2027 Hospital Inpatient PPS Final Rule.

This rule included an update significant to Skilled Nursing Facilities.

 

CJR-X (Comprehensive Joint Replacement – Expanded)

  • CJR: Comprehensive Joint Replacement, was a Medicare A bundling model that ran for 8 years from 2016 – 2024 in 34 locations in 20 states.
  • It included only one diagnosis: LEJR: Lower Extremity Joint Replacement (hip & knee).
  • Due to its success in reducing spending without reducing quality, CMS is now expanding this model nationwide.
  • CJR-X will be the first bundling model that will be mandatory nationwide for all hospitals in the 50 states with very limited exceptions.
  • The episode of care is the hospital plus 90 days post-acute care, which includes any applicable SNF stay!
  • Hospitals will receive reward payments if they reduce spending while still meeting certain quality measures.

 

How does this affect the SNF?

  • Hospitals will want to partner with preferred SNF providers who have good Quality Measure performance and few re-hospitalizations.
  • Hospitals will try to divert patients home and away from the SNF, and require shorter LOS for those residents who do admit to the SNF.
  • SNFs with 3 or more starts may utilize the 3-Day waiver for these patients.

 

CJR-X is scheduled to begin January 1, 2028.

The FY 2027 IPPS and LTCH PPS final rule (CMS-1849-F) can be viewed on the Federal Register at: https://www.federalregister.gov/d/2026-15833

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

Medicarequestions@enhancetherapies.com

IMPORTANT CMS UPDATE: 08/06/2026 – QRP NON-COMPLIANCE LETTERS for FY2027

QRP NON-COMPLIANCE LETTERS for FY2027

CMS posted notifications for Facilities who were deemed out of compliance with CY 2025 QRP reporting requirements. This will reduce their FY2027 Medicare A rates which begins on Oct 1, 2026.

 

Non-compliance notifications were placed into Facilities’ “My Reports” folders in iQIES on Aug 5, 2026.

 

Facilities who receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, September 4, 2026.

We recommend that Facilities check this folder as soon as possible.

 

If you received a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP webpage:

 

IMPORTANT CMS UPDATE: 08/05/2026 – FY2027 VBP Performance and Payment Multiplier Now Available

FY2027 VBP Performance and Payment Multiplier Now Available

FY2027 VBP Performance Score Reports are now available in iQIES.

 

This report indicates your Medicare A Payment Multiplier for FY2027 which will begin on October 1, 2026.

 

FY2027 payment rewards are based on SNF performance in 2025

As a reminder, this is the first year that GG DC Function Performance will affect the Medicare rate.

 

The FY2027 program has 8 VBP Measures:

  1. 30-Day SNF Re-Admissions (SNFRRM)
  2. SNF Acquired Infections Requiring Hospitalization (SNF HAI)
  3. Successful Discharge to Community (DTC)
  4. Long Stay Hospitalization
  5. Nursing Staff Turnover
  6. Total Nursing Hours 
  7. Discharge Function Score
  8. Falls with Major Injury – Long stay

 

Interpreting the Results: 

  • Tab 2: Overview of Performance:
    • This tab indicates your SNF’s Performance in each of the 8 measures.
    • It also shows how your current performance compares to your prior performance, (ie did you improve or decline), as well as how you compare to National performance.
  • Tab 5: Performance Score
    • This tab sums up your performance points across all measures for your Total VBP Score and National Ranking.
  • Tab 6: Incentive Payment Multiplier – Most important tab!
    • This tab Indicates your Final Payment Multiplier for FY2027; this is the number in cell B7. This number will be multiplied by your Med A rate in 2027 to determine final Med A payment.
      • If it is higher than 1.0, you will receive more than 100% of the Med A Rate. Eg, if the multiplier is 1.01, you will receive 101% of the Med A rate in 2027.
      • If it is lower than 1.0, you will receive less than the full Med A Rate. Eg, if the multiplier is 0.985, you will receive 98.5% of the Med A Rate in 2027.

To locate your VBP Performance Report:

  1. Log into iQIES at https://iqies.cms.gov/.
  2. In the Reports menu, select My Reports.
  3. From the My Reports page, locate the MDS 3.0 Provider Preview Reports folder. Select the MDS 3.0 Provider Preview Reports link to open the folder.
  4. Locate the SNF VBP Program Performance Score Report (file name: SNFVBP_[CCN]_FY2027_IPM_AUG2026PSR.xlsx).
  5. Once located, select More next to your desired SNF VBP Program Performance Score Report and the report will be downloaded through your browser.

For more information about the SNF VBP Program, please visit the CMS website:https://www.cms.gov/medicare/quality/nursing-home-improvement/value-based-purchasing

 

If you would like assistance with interpreting your VBP reports, please email Medicarequestions@enhancetherapies.com

IMPORTANT CMS UPDATE: 08/03/2026 – FY2027 SNF PPS Final Rule Released

FY2027 SNF PPS Final Rule Released

The FY2027 SNF PPS Final Rule was released on July 29, 2026.

Virtually all items mentioned in the Proposed Rule back in April were finalized in this Rule.

Below is a summary of key items:

 

A. PDPM Rates

  • For FY2027, CMS is increasing SNF PPS rates by 2.4% as originally proposed.  
  • CMS estimates that the overall impact is an estimated increase of $882 million in aggregate payments to SNFs. Each SNF, however, will be affected differently based on their specific wage index.

B. ICD-10 Codes:

  • CMS did not make any substantive changes to the Clinical Category mapping of PT/OT, SLP comorbidities, or NTA.

 

C. Quality Reporting Program (QRP)

  • CMS finalized the removal of the 2 COVID related QRP Measures for QRP Reporting:
  1. Percent of Residents who are Up to Date with their COVID Vaccination (submitted through MDS item O0350). This may be stopped with new admissions as of Oct 1, 2026.
  2. COVID-19 Vaccination Coverage Among Healthcare Personnel (submitted through NHSN). This may be stopped for calendar year 2026.
  • Beginning with calendar year 2027, (Jan 1, 2027), CMS is revising the QRP submission/correction deadline from 4.5 months to 45 days after the end of the quarter. This means that SNFs must be more vigilant about MDS timeliness and accuracy and make corrections as soon as possible. The new deadlines are as follows:
  • 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:

IMPORTANT CMS UPDATE: 06/04/2026 – VBP Performance Reports Now Available in iQIES​

VBP Performance Reports Now Available in iQIES

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.

To locate your report in iQIES:

  1. Log into iQIES
  2. In the Reports menu, select My Reports.
  3. From the My Reports page, locate the MDS 3.0 Provider Preview Reports folder.  Select the MDS 3.0 Provider Preview Reports link to open the folder.
  4. Locate the desired SNF VBP Program Quarterly Confidential Feedback Report.
  5. Select More next to your desired SNF VBP Program Quarterly Confidential Feedback Report and the report will be downloaded through your browser. Once downloaded, open the file to view your facility’s report.

For more information about the SNF VBP Program, please visit the CMS website: https://www.cms.gov/medicare/quality/nursing-home-improvement/value-based-purchasing

 

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

Medicarequestions@enhancetherapies.com.

SNF Bundling Models: What Every Skilled Nursing Facility Needs to Know

SNF Bundling Models: What Every Skilled Nursing Facility Needs to Know

Category: Reimbursement & Regulatory | Audience: SNF Operators, Administrators, DONs, Billing Teams


On April 10, 2026, CMS released the FY2027 Hospital Inpatient PPS Proposed Rule — and buried inside it were two updates that every skilled nursing facility in the country needs to understand: changes to the TEAM Bundling Model and a proposed nationwide expansion called CJR-X.

If your facility receives referrals from acute care hospitals — and nearly every SNF does — these models will affect your census, your referral relationships, and your Medicare revenue. Here’s everything you need to know.


What Is SNF Bundling?

Bundling is a Medicare payment model designed to reduce costs by holding hospitals financially accountable for the total cost of a patient’s care episode — from admission through post-acute recovery.

CMS sets a “target price” for each bundled episode. That episode includes the hospital stay and all Medicare Part A and Part B costs through 30 days post-hospital discharge — which includes your SNF stay.

  • If the total episode cost comes in under the target price, CMS shares the savings with the hospital.
  • If costs come in over the target price, the hospital may owe CMS the difference — or at minimum, forfeits any bonus payment.
  • Hospitals must also meet quality performance thresholds to receive any savings reward.

The hospital controls the money. But the pressure lands squarely on post-acute providers.


The TEAM Model: What SNFs Need to Know Now

The Transforming Episode Accountability Model (TEAM) is a mandatory CMS bundling program that launched January 1, 2026 and runs through December 31, 2030.

Which Diagnoses Are Included?

TEAM covers five diagnoses:

  • Coronary Artery Bypass Graft (CABG)
  • Major Bowel Procedure
  • Lower Extremity Joint Replacement (LEJR)
  • Surgical Hip and Femur Fracture Treatment (SHFFT)
  • Spinal Fusion

Any patient who discharges from a TEAM-participating hospital with one of these diagnoses is automatically included in the model — regardless of where your SNF is located. What matters is the location of the discharging hospital, not your facility.

 

Which Hospitals Are Participating?

721 hospitals across 44 states, Washington D.C., and Puerto Rico are participating in TEAM — 189 mandatory locations plus 10 voluntary participants.

You can check whether your referral hospitals are on the list at cms.gov/team-model-participant-list.

What Does This Mean for Your SNF?

Once a hospital is financially accountable for the full episode cost, their behavior toward post-acute partners changes. Here’s what to expect:

Preferred provider pressure. Hospitals will actively seek SNF partners with strong quality measure performance. If your Five-Star rating, readmission rates, and discharge function scores aren’t where they need to be, you may find referral streams shifting.

Length-of-stay expectations. Hospitals will push for shorter SNF stays for patients with these five diagnoses. Your clinical team needs to be prepared to demonstrate the value of each additional day.

Home health diversion. Hospitals may attempt to route bundled patients directly to home health rather than SNF-level care. Know your differentiators and be ready to make the case for skilled nursing when it’s clinically appropriate.


The 3-Day Waiver Opportunity

Here’s an opportunity many SNFs are leaving on the table.

When a patient discharges from a TEAM-participating hospital with one of the five bundled diagnoses, your SNF may be able to skill them under Medicare A — even with a very short or no qualifying hospital stay.

Key details:

  • These patients can be billed under Medicare A with only a 1 or 2-day hospital stay, or even no hospital stay at all.
  • Your SNF must have a 3-star rating or higher for at least 7 out of the past 12 months to be eligible for the waiver.
  • Billers must enter “A9” in Treatment Authorization Field (63) of the UB04 to bypass the standard 3-day requirement.

If your facility qualifies and your referral hospitals are TEAM participants, this represents a meaningful census and revenue opportunity — but only if your billing team knows to act on it.

Note for Enhance Therapies partner facilities: A separate payer can be added for these residents in the system upon request. Contact your Enhance Therapies clinical or billing liaison for support.


CJR-X: The First Nationwide Mandatory Bundling Model

The original Comprehensive Joint Replacement (CJR) model ran from April 2016 through December 2024, covering hip and knee replacements in 34 locations across 20 states. CMS deemed it a success — costs went down without a reduction in quality.

Now CMS is proposing to go much bigger.

CJR-X would expand the model to virtually every eligible acute care hospital in the country, covering Lower Extremity Joint Replacement (hip and knee replacements). Hospitals already participating in TEAM would be excluded, as would acute care hospitals in Maryland due to their unique rate-setting structure — but almost every other hospital would become a mandatory participant.

If finalized, CJR-X would be the first-ever nationwide mandatory bundling model — meaning the referral dynamics described above for TEAM would apply to hip and knee patients at nearly every hospital that sends you referrals.


How to Prepare Your SNF

The facilities that will thrive under bundling models are those that can demonstrate value to hospital partners through measurable outcomes. Here’s where to focus:

1. Know your quality scores. Pull your Five-Star rating, readmission rates, and discharge function scores today. These are the metrics hospitals will use to evaluate preferred SNF partners.

2. Check your referral hospitals. Review the TEAM participant list and identify which of your referral sources are already in the model. Those relationships are changing — get ahead of it.

3. Brief your billing team. The 3-day waiver is a real opportunity for qualifying facilities. Make sure your billers know the A9 code and the UB04 field requirement before your next eligible admission.

4. Prepare for LOS conversations. Develop clinical documentation protocols that clearly support the medical necessity of each day of skilled care for the five TEAM diagnoses.

5. Track CJR-X. The proposed rule is still in comment period. Final rule decisions will shape whether and when CJR-X takes effect. Stay informed.

IMPORTANT CMS UPDATE: 3/23/2026 – New ABN Form Now Available

New ABN Form Now Available

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)

CMS has now finalized the new ABN form which has a new expiration date of March 31, 2029.

Providers may continue to use the expired form until May 12, 2026, but must transition to the new form after that.

 

As a reminder, the CMS-R-131 ABN form is for Med B patients only 

(The Med A SNF-ABN form which is called CMS-10055, was revised in Oct 2024 and has no new changes)

 

An ABN allows a patient to accept financial responsibility for a non-covered service.  

 

For Med B, it is typically used when skilled therapy ends secondary to being no longer clinically indicated, but the patient requests continued treatment. 

The ABN allows the patient to accept full financial responsibility for the services, or to ask the facility to first bill Medicare and pay only if services are denied.

 

It is important to note that the facility may only bill the patient if an ABN was provided prior to the provision of the non-covered services.  

The biller must then append a “GA modifier” to the billing to let Medicare know that the ABN was given. 

 

Revisions include minor changes and simpler language.

The ABN form is available in English and Spanish.

 

The new forms have been added to the Enhance Therapies’ website and common share.

 

To see the new forms and ABN instructions: https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn

 

If you have questions or need additional information, please email us at: Medicarequestions@enhancetherapies.com

IMPORTANT CMS UPDATE: 1/29/2026 – Revisions to the Special Focus Facility Program

Focus on FALLS - Revisions to the Special Focus Facility Program

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

IMPORTANT CMS UPDATE: 1/14/2026 – QRP & VBP Validation Audits Have Begun!

QRP & VBP Validation Audits Have Begun!

As promised, CMS has begun their QRP and VBP Data Validation Program!  

The first request letters were posted on January 12th!

This is a Medicare A program whose purpose is to validate the assessment based measures used for QRP and VBP.

CMS will compare MDS entries against a patient’s medical records to ensure that the MDS data used to calculate measures and payment is accurate. 

As a reminder:

  • Each year, CMS will randomly select 1500 facilities to review
  • Up to 10 charts will be requested 
  • Records should be submitted electronically through a secured provided link that facilities will receive with their notification
  • The SNF has 45 calendar days to submit the records or be subject to a 2% Med A penalty!

Facility selection notices will be posted in: iQIES > My Reports> MDS 3.0 Provider Preview Reports folder.  

When a facility receives a selection notice they must: 

  • Set up primary and secondary Point of Contacts (POC) at the facility who will receive and respond to validation related communication 
  • Complete the POC form within 5 business days 

We strongly recommend that providers check their iQIES folder as soon as possible, and then continuously thereafter, to see if they received a selection notification. There is no separate email that goes out, so you must check this folder often!!

CMS created a 14 minute YouTube video to explain the program.  

This can be accessed at: https://youtu.be/B20RF412eug  

CMS also created an FAQ document to answer questions: https://www.cms.gov/files/document/data-validation-process-frequently-asked-questions-12-17-2025.pdf

As always, if you have questions, or need additional information, please email us at: Medicarequestions@enhancetherapies.com

IMPORTANT CMS UPDATE: 12/24/2025 – SNF Validation Audits Deferred to Mid-January 2026

SNF Validation Audits Deferred to Mid-January 2026

In the FY2024 Final Rule, CMS indicated that they would begin to perform Validation Audits aimed at evaluating the accuracy of MDS items used for Quality Measure scoring in the SNF QRP and VBP Programs.

These audits were originally set to begin Fall of 2025, but are being deferred until mid-January 2026.

  • As a reminder, the SNF QRP Program is a reporting program to ensure key data is properly reported. Facilities who fail to meet certain reporting thresholds are subject to a 2% Medicare A penalty.
  • The SNF VBP program is a performance program where providers are paid based on measure performance. Providers can receive up to a 2% Medicare A reward OR penalty based on their performance of certain quality measures.

CMS is instituting a NEW validation process set to begin this January, to ensure that the MDS items used to calculate SNF QRP and VBP payments to SNFs are accurate.

  • CMS will randomly select up to 1,500 SNFs each year
  • 10 charts will be requested and the SNF has 45 days to submit the records or be subject to a 2% Med A penalty
  • At a later date, penalties may also be imposed for not achieving specified accuracy thresholds

CMS released an informative FAQ document on the Validation Program, and we suggest Facilities review it:

https://www.cms.gov/files/document/data-validation-process-frequently-asked-questions-12-17-2025.pdf

  • The document directs SNFs to submit a POC – Point of Contact to CMS designated to receive audit related email notifications.
  • Unlike regular ADR requests that are relayed through the billing system, notification for these audits will be through the IQIES MDS 3.0 Provider Preview Reports folder. Facilities must continuously check this folder to avoid late submissions and penalties. 

As a reminder, Enhance Therapies has a comprehensive Claims Department to assist with these reviews, but early notification is essential!

If you have questions, or need additional information, please email us at: Medicarequestions@enhancetherapies.com