Nurse leaders will need to do short-, mid-. and long-range planning to successfully implement the new and revised policies for the Skilled Nursing Facility Quality Reporting Program (SNF QRP) and the Skilled Nursing Facility Value-Based Purchasing program (SNF VBP) in the Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule for Fiscal Year (FY) 2027. Understanding the changes associated with the following three dates will help nurse leaders get a head start on both short-term and mid-range preparation:
Oct. 1, 2026: COVID-19 Vaccine reporting for the SNF QRP can end
This final rule removes two quality measures (QMs) related to COVID-19 from the SNF QRP beginning with the FY 2028 (Oct. 1, 2027 – Sept. 30, 2028) program year due to changes in clinical practice guidelines, changes in vaccination recommendations from the Centers for Disease Control and Prevention (CDC), and other factors. These measures are as follows:
* The COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP COVID-19 Vaccine) QM that is reported through the CDC’s National Healthcare Safety Network (NHSN). The data collection period for FY 2028 is calendar year (CY) 2026, meaning it is currently ongoing. With this finalized proposal, SNFs are no longer required to report CY 2026 data for the HCP COVID-19 Vaccine for the FY 2028 payment determination.
“That is, SNFs that do not report CY 2026 HCP COVID-19 Vaccine measure data will not be penalized for the FY 2028 annual payment update [APU] under the SNF QRP,” says the Centers for Medicare & Medicaid Services (CMS). “Any CY 2026 HCP COVID-19 Vaccine measure data received by CMS would not be used for SNF QRP compliance or public reporting.”
Using Q4 2025 data, the HCP COVID-19 Vaccine measure will be publicly reported for the last time with the October 2026 Care Compare refresh. After that, CMS will no longer display a SNF’s HCP COVID-19 Vaccine measure data on Care Compare.
In effect, then, SNFs may end CY 2026 HCP COVID-19 Vaccine measure data reporting immediately because CMS will not obtain any CY 2026 data for this measure—even data that is voluntarily submitted to the NHSN. However, the safest course since CMS does not explicitly say that reporting can end on a specific date is to wait for the effective date of the FY 2027 SNF PPS final rule and end submissions on Oct. 1, 2026.
“[R]emoval of the measure from the SNF QRP has no bearing on the SNF’s ability to continue tracking vaccination surveillance data to understand the impact on infection prevention activities in their facility and does not alter any separate documentation or reporting requirements such as those that may be required under 42 [Code of Federal Regulations] CFR 483.80,” stresses CMS.
* The COVID-19 Vaccine: Percent of Patients/Residents Who Are Up-to-Date (Patient/Resident COVID-19 Vaccine) measure that is reported through the MDS. SNFs will no longer be required to collect and submit data for this measure beginning with residents discharged on or after Oct. 1, 2026, says CMS. MDS item O0350 (Resident’s COVID-19 Vaccination Is Up to Date) will remain on the MDS item sets until Oct. 1, 2027 “since it is not technically feasible to remove this data element earlier.” However, reporting will become voluntary beginning with residents discharged on or after Oct. 1, 2026.
The last time that this measure will be publicly reported is with the October 2026 Care Compare refresh using data from Q4 2025. Voluntarily reported data will not be publicly reported, adds CMS.
Despite commenters’ concerns, removal of this measure should not reduce transparency and weaken infection prevention accountability, says CMS. “SNFs [still] must establish an infection prevention and control program (IPCP) per §483.80(a) and must designate one or more individuals as the infection preventionist (IP) who are responsible for the IPCP per §483.80(b). Finally, the SNF QRP does include the SNF Healthcare-Associated Infections (HAI) Requiring Hospitalizations (SNF HAI) measure.”
May 17, 2027: First SNF QRP assessment data submission deadline change
Effective Jan. 1, 2027, the final rule revises the SNF QRP assessment data submission deadline—for both MDS assessment data and NHSN assessment data—to no later than the 15th day of the second month after the end of each calendar quarter beginning with the FY 2029 (Oct. 1, 2028 – Sept. 30, 2029) SNF QRP. Basically, that shrinks the window for meeting the data submission deadline from 4.5 months after the end of the data collection period to only 45 days. This deadline will be adjusted when the 15th day of the second month falls on a Friday, weekend, or federal holiday. In that case, the date is delayed until 11:59 p.m. Eastern Standard Time (EST) on the next business day.
However, SNFs that are unable to submit finalized, corrected SNF QRP data timely due to a natural or man-made disaster or other extraordinary circumstances will still be able to request an exception or extension via e-mail by following the instructions here within 90 days of the extraordinary circumstances event, according to CMS.
The first new quarterly deadline for FY 2029 will overlap with pre-existing data collection requirements for FY 2028. Data collection for Q1 FY 2029 runs Jan. 1 – March 31, 2027. The revised deadline for Q1 will be May 17, 2027—the same date that SNF QRP data for Q4 FY 2028 (Oct. 1 – Dec. 31, 2026) will be due, according to the Data Collection & Final Submission Deadlines for the FY 2028 SNF QRP.
The following chart adapted from tables 13 and 14 in the final rule explains the FY 2029 SNF QRP assessment deadlines and demonstrates how future FYs will work:
| MDS (applies to all required MDS data) | ||
| Calendar Year (CY) Data Collection Quarter Associated With FY 2029 | Data Collection Timeframe | Final Data Submission Deadlines for FY 2029 Payment Determination |
| CY 2027 Quarter 1 | Jan. 1 – March 31, 2027 | May 17, 2027 |
| CY 2027 Quarter 2 | April 1 – June 30, 2027 | Aug.16, 2027 |
| CY 2027 Quarter 3 | July 1 – Sept. 30, 2027 | Nov. 15, 2027 |
| CY 2027 Quarter 4 | Oct. 1 – Dec. 31, 2027 | Feb. 15, 2028 |
| NHSN | ||
| Measure | Data Collection Timeframe for FY 2029 | Final Data Submission Deadline for FY 2029 Payment Determination |
| Influenza Vaccination Coverage Among HCP | Oct. 1, 2027 – March 31, 2028 | May 15, 2028 |
CMS believes that this revision represents a “reasonable” timeframe for data submission on both platforms because there is no additional burden for NACs and other staff. Rather, the new deadline “shifts the existing workflow to a different time point,” and CMS expects the CY 2027 implementation to give providers “sufficient time to address operational or staffing changes that may be required.”
While one commenter noted that many SNFs “rely on external vendors to validate MDS and NHSN submissions prior to final transmission” and that these external reviews “may no longer be feasible within a 45-day submission window,” CMS points out that external data validations are not required, stating that “[i]n general, we expect data validation and quality checks to be complete with the initial data submission, with better proximity to the patient.”
Note: Nurse leaders that have questions about the SNF QRP data submission requirements can submit them at [email protected]. Additional contact information is available at CMS’s SNF QRP Help page.
Nov. 15, 2027: First SNF VBP MDS snapshot date change
The two-phase SNF VBP review and correction process allows SNFs to submit requests for corrections to the measure results in Phase One and to submit requests for corrections to the SNF performance score and ranking in Phase Two. However, facilities must correct the underlying data that goes into the SNF VBP QMs much earlier—by specified “snapshot dates”—to ensure that it is reflected in the SNF VBP quarterly confidential feedback reports.
To align the SNF VBP snapshot dates for MDS-based QMs with the SNF QRP’s revised assessment data submission deadlines, CMS is finalizing new, shortened snapshot dates based on the SNF QRP deadline changes. Two MDS-based measures will be impacted “beginning with data collected in FY 2027” (Oct. 1, 2026 – Sept. 30, 2027):
- Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay) (Falls With Major Injury (Long-Stay)), and
- Discharge Function Score for SNFs (Discharge Function Score).
Currently, the snapshot date is the Feb. 15th that is 4.5 months after the last day of the applicable baseline or performance period, says CMS. “However, if Feb. 15th falls on a Friday, weekend, or federal holiday, the snapshot date is delayed until 11:59 p.m. EST on the next business day.”
CMS gives an example in the final rule that looks at FY 2025 (Oct. 1, 2024 – Sept. 30, 2025), which is the performance period for the upcoming FY 2027 (Oct. 1, 2026 – Sept. 30, 2027) SNF VBP program year, and its snapshot date of Feb. 17, 2026. Building upon that, the ongoing FY 2026 (Oct. 1, 2025 – Sept. 30, 2026) is the performance period for the FY 2028 SNF VBP. The snapshot date for the FY 2026 performance period will be Feb. 16, 2027 because Feb. 15, 2027 is a federal holiday.
Continuing to work out from the CMS example, FY 2027 (Oct. 1, 2026 – Sept. 30, 2027) is the performance period for the FY 2029 (Oct. 1, 2028 – Sept. 30, 2029) SNF VBP. Data collected in FY 2027 will be subject to the revised snapshot date that is basically 45 days after the close of the data collection period. So, the snapshot date for FY 2027 data on the SNF VBP’s MDS-based measures will be Nov. 15, 2027 instead of Feb. 15, 2028. SNFs will need to submit any necessary corrections to FY 2027 MDS data via the Internet Quality Improvement Evaluation System (iQIES) by this new snapshot date.
While some technical specifications may vary, the Falls With Major Injury (Long-Stay), and Discharge Function Score QMs are in both the SNF QRP and the SNF VBP measure sets. So, any timely corrections to the underlying MDS items will affect SNF performance in both programs. However, it’s worth noting that the SNF VBP will maintain an annual deadline while the SNF QRP has quarterly deadlines. In the event of internal system failures, then, a SNF may still be able to correct some MDS data to support SNF VBP performance even after it can no longer be corrected for the SNF QRP—as long as the appropriate snapshot date is met.
For example, SNFs will need to report required MDS data for Jan. 1 – March 31, 2027 by May 17, 2027 for the SNF QRP. However, SNFs will be able to continue to correct Jan. 1 – March 31, 2027 MDS data (when appropriate) through Nov. 15, 2027 for the SNF VBP.
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