PBJ technical specifications changed
Our Take: CMS made minor updates to the PBJ data specification for uploaded PBJ files. Users can no longer submit more than 22.5 hours per employee ID. XML files are…
Our Take: CMS has proposed a 2.4% Medicare rate increase for SNFs in FY 2027 while simultaneously expanding MDS data collection to all payer types and launching a formal VBP data validation process. These developments signal tighter reimbursement margins and heightened scrutiny of quality reporting accuracy. ▼
Stakeholders across the sector are pushing back on inadequate pay rates. SNFs should prepare for active CMS and OIG auditing of PDPM coding and HIPPS code accuracy – all of which directly affect VBP incentive payments, Five-Star ratings, and exposure to repayment demands.
What SNFs Should Do Now to Protect Themselves in a New Era of CMS Validation and OIG Enforcement
As of January 2026, CMS has officially launched its SNF VBP Data Validation Process, and randomly selected facilities have been receiving notices through iQIES since mid-January. At its core, the validation process evaluates the accuracy of quality measure data elements derived from the MDS. A recent OIG audit found that nearly all sampled claims — 99 out of 100 — for skilled nursing services did not meet Medicare payment requirements, with the OIG estimating that Pinnacle received at least $31.2 million in overpayments during calendar years 2020 and 2021.
— McKnight’s Long-Term Care News, April 10, 2026
Nursing Homes Brace for a Million-Hour Quality Reporting Data Surge
Providers could spend more than one million additional hours collecting and submitting data annually to comply with proposals included in the fiscal 2027 skilled nursing pay rule. Starting in 2031, CMS wants to require nursing homes to conduct and submit MDS assessments for all patients, regardless of whether they are covered by an Institutional-Special Needs Plan or any commercial Medicare Advantage plan — resulting in an estimated 1.1 million more MDS forms per year. The number of providers hit by the 2% payment penalty for late QRP data has soared from 298 nursing homes in fiscal 2024 to 2,285 in fiscal 2026.
— McKnight’s Long-Term Care News, April 6, 2026
[Updated] CMS Proposes 2.4% Medicare Increase for Skilled Nursing Facilities in 2027
The 2.4% increase is based on the proposed SNF market basket of 3.2% and a negative 0.8% productivity adjustment. LeadingAge SVP of Policy Linda Couch said the proposed increase “barely keeps up with inflation,” and that inadequate reimbursement “threatens the ability of quality-focused, mission-driven providers to deliver needed care.” CMS is also proposing to remove two Covid-19 vaccination measures from the SNF QRP beginning in 2028, and to require MDS data submission for all residents receiving skilled care regardless of payer, beginning with FY 2031.
— Skilled Nursing News, April 2, 2026
MedPAC Commissioners Cautious About Post-Acute Regulation, Pay
Medicare Payment Advisory Commission members offered a variety of recommendations and research wishes in response to a staff report on post-acute trends and issues. Commissioners showed significant interest in how the TEAMS alternative payment model will perform and largely agreed more needs to be done to keep Medicare Advantage plans better in check, particularly with regard to prior authorization practices. Multiple commissioners also expressed interest in amending or eliminating the three-night hospital stay requirement to gain Medicare coverage for SNF care.
— McKnight’s Long-Term Care News, December 7, 2025
DNS Takeaways From the FY 2026 SNF PPS Proposed Rule
CMS projects that overall SNF PPS payments will increase by approximately 2.8 percent in FY 2026, though urban vs. rural providers in different regions are expected to see vastly different payment updates. Failure to meet either the annual MDS data submission threshold or the separate NHSN data submission threshold will trigger a 2 percent cut in FFS Part A payment rates in the applicable program year — a penalty that could result in a negative payment update for any provider whose annual increase is less than 2 percent. CMS is also considering reducing the QRP data submission timeframe from 4.5 months to 45 days following the end of the quarter.
— AAPACN, July 8, 2025
Stakeholders Unload Big List of Nursing Home Deregulation Wishes as CMS Deadline Hits
LeadingAge criticized the automatic levying of a 1-star rating for staffing if Payroll-Based Journal workforce information isn’t submitted in a timely enough manner, calling it a “growing tendency” to use Care Compare and the Five-Star Quality Rating System for enforcement purposes they weren’t designed for. AHCA’s 54-page submission included a request to stop forced rating downgrades to 1-star as a PBJ audit penalty, shift to a 20% allotment at each star rating, and move to a two-survey cycle rather than three.
— McKnight’s Long-Term Care News, June 10, 2025
Providers Appeal for Better Pay, New Wage Index but Wary About Tech in Final SNF Rule
Payroll-Based Journal data, which has been collected for nearly 10 years, can form a better index that “reflects true labor costs,” AAPACN leaders said. “The result could be more equitable and accurate reimbursements, particularly for facilities struggling with rising wages or changes in their wage index.” AHCA also warned that without a SNF-specific wage index, costs associated with the federal nursing home staffing mandate would lead to reduced access for patients, noting that nursing homes still need more than 42,700 workers to return to pre-pandemic employment levels.
— McKnight’s Long-Term Care News, June 10, 2025
CMS Proposes 2.8 Percent Skilled Nursing Pay Raise for 2026
The fiscal 2026 SNF PPS proposed rule calls for a 3% market basket adjustment to account for inflation, plus a 0.6% forecast error adjustment and -0.8% productivity reduction. CMS also proposed removing four standardized patient assessment data elements from the Social Determinants of Health category beginning October 1, 2025, and introduced a new VBP appeals process allowing providers to request reconsideration if dissatisfied with a review and correction decision.
— McKnight’s Long-Term Care News, April 11, 2025
