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