The Skilled Nursing Facility (SNF) Quality Reporting Program (QRP), often regarded as merely an exercise in reporting compliance, also has direct payment implications. Thus for SNFs, compliance reflects both quality and financial issues. The program asks facilities to report all the required data on at least 90% of the mandated Medicare assessments and report 100% of the National Healthcare Safey Network (NHSN) data to comply.
In fiscal year (FY) 2026, nearly 15% of facilities nationwide lost 2% of their Annual Payment Update (APU) due to noncompliance. Although the national pattern of noncompliance is not alarming, some states fared much worse than the national average. This article reviews state-level SNF QRP compliance performance and offers strategies on how facilities can improve their reporting efforts.
The national picture
The first takeaway is that national SNF QRP compliance is respectably strong but could be improved. The Centers for Medicare & Medicaid Services (CMS) released three files listing facilities deemed as in compliance, noncompliant, or excluded for the FY 2026 SNF QRP program. The files list 15,459 SNFs and swing beds. Analysis reveals that 80% of SNFs are compliant nationally, so nearly 1 in 5 facilities are still either noncompliant or excluded.
Only 5% of facilities nationally are excluded, either due to termination or no Medicare data. This leaves just under 15% of all facilities penalized for not reporting the data required for SNF QRP compliance, possibly a result of gaps in processes, education, follow-up, or all three. However, the file does not provide enough information to fully explain the root cause of noncompliance.
The state view
Although the national performance for compliance was 80%, the average compliance among all states and several U.S. territories lowered the number to 77%. That matters because it suggests the national challenge is not limited to a few extremely poor performers. Most states are landing in a midrange zone where improvement is possible but not automatic. With the exception of Guam (100% compliance due to its one facility meeting thresholds), no other state or territory exceeded 90% compliance. These numbers imply that systematic barriers in the program structure may be preventing overall success and compliance.
For organizational leaders in long-term care, the opportunity is not just to rescue the lowest performers, for example how they may approach quality improvement efforts, but to help facilities more broadly move from “usually compliant” to “reliably compliant.”
Top performing states
The top 10 performing states, excluding low-volume territories, are Alabama, Arkansas, California, Idaho, Nevada, New Jersey, Virginia, West Virginia, South Dakota, and Texas. These states range from 84% to 89% compliance, with an average of 86%. The states also widely vary in volume of facilities. Texas and California both have more than a thousand facilities; Idaho and South Dakota have less than a hundred. The top 10 also encompass all area of the United States: the East Coast, South, Midwest, and West Coast. The best performers are both states that are majority urban (e.g., California, 97% urban) and states that are majority rural (e.g., South Dakota, 70% rural), according to data.cms.gov.
Understanding this data is key for success. First, it shows that stronger performance is achievable across different markets and geographic locations. These are not all large states, small states, urban-heavy states, or states with identical provider mixes. Second, the results suggest that the biggest differentiator may be process discipline rather than circumstance alone.
Facilities in these states are not necessarily facing fewer reporting demands. More likely, they have stronger systems to track required assessments, correct dashes before deadlines, monitor Internet Quality Improvement and Evaluation System (iQIES) submissions, and manage NHSN reporting expectations. In practice, top-tier performance usually reflects stronger process systems and more routine accountability.
States with opportunity
At the lower end, two states exceeded 30% noncompliance: Minnesota and New Mexico. Three more exceeded 25%: Maine, Georgia, and Oregon. Like the top performers, these states are not especially similar, ranging from 79 to 388 total facilities in each state and spread out across the nation geographically. With the average noncompliance across all states and territories at 16%, this level of noncompliance should not be dismissed. Because the analysis showed no similarities based on external factors, it may signal other barriers, such as staffing instability, accountability, weak audit processes, insufficient care transition processes, or other systematic breakdowns.
When a facility is reviewing noncompliance, a missed clinical assessment, an unresolved dash, or a failure to complete required NHSN reporting may look like a one-off error at the resident level. But when the team takes a step back and reviews the systems that impacted noncompliance in perspective, it may indicate a more widespread systematic root cause. Facilities that were noncompliant should review workflows, care transitions, facility-hospital care coordination, education, and real-time monitoring.
Improvement efforts
Improving SNF QRP compliance ultimately is really less about chasing percentages and more about strengthening the reliability of everyday processes. Facilities that consistently meet reporting thresholds are not necessarily doing more work, but they have more consistent systems. They may have more effective delegation of required data elements, defined workflows for assessment completion and submission, and routine checkpoints to catch errors before deadlines pass. Just as importantly, facilities must reinforce that QRP compliance is not the responsibility of one role but rather a shared expectation across the interdisciplinary team.
Conclusion
SNF QRP compliance sits at the intersection of quality care, regulatory expectations, and financial stability. Although national performance shows that many facilities are meeting requirements, the variation across states highlights an important truth: reliable compliance is achievable, but it requires intentional systems, not chance.
To move from “generally compliant” to “consistently compliant,” facilities must focus on the fundamentals: timely assessment completion, accurate MDS coding, proactive audit processes, and clear accountability for NHSN reporting. These are not new concepts, but they are often where breakdowns occur.
It pays to remember that behind every missed data point is not just a reporting gap, but a missed opportunity to reflect the resident’s care and outcomes accurately. By strengthening processes, reinforcing team ownership, and using data to guide improvement, facilities can protect reimbursement, support compliance, and, most importantly, ensure that the story conveyed by their data truly represents the care they provide every day.
Tools: The AAPACN QM Rescue Guide can help the team investigate the root cause and clinical systems needed to make improvements.
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