As the federal government shutdown nears its end, now is the time for skilled nursing providers to sharpen their readiness for what’s coming next: targeted audits of MDS-based quality data. Compliance can no longer be an after-thought.
Why Now?
The Centers for Medicare & Medicaid Services (CMS) has launched the Skilled Nursing Facility Validation Program (SNF Validation Program) to verify the accuracy of data that facilities submit through the Minimum Data Set (MDS) 3.0—the resident assessment tool used in skilled nursing settings. In short: if you assess even a single resident via MDS in 2024 or 2025, you’re eligible for selection. Fail to respond appropriately, and your facility could face a 2% reduction in its annual payment update.
What to Expect
Here’s a breakdown of what the audit process will look like:
- Facilities are randomly chosen among those submitting at least one MDS record in the prior and current fiscal year.
- Auditors (Healthcare Management Solutions, LLC) will request medical chart documentation for up to 10 sampled MDS assessments.
- Facilities have 45 calendar days from notification to submit requested records.
- Documents must be uploaded in PDF format through the secure portal and must exclude resident Social Security numbers and face sheets.
- Failure to submit within the timeframe triggers noncompliance and payment reduction.
Strategic Steps to Prepare — Before the Notice Arrives
- Check iQIES frequently for audit notifications.
- Assign a Point of Contact (POC) and ensure their information is current.
- Audit MDS-to-chart documentation.
- Ensure EHR workflows capture supportive documentation.
- Integrate QAPI/QAA processes to review MDS accuracy.
- Educate your interdisciplinary team (IDT).
What to Watch Out For
- Small facilities are also selected—random means random.
- Dashes and “unknown” responses on the MDS are risky.
- Misalignment between medical records and MDS entries increases audit risk.
- Non-submission—not data errors—triggers financial penalties.
- Documentation must match the MDS exactly.
- Missing or inconsistent interviews can create exposure.
Limitlessli’s Mary-Beth Newell, SVP of Clinical Reimbursement, advises:
“Treat this as a planned audit event. Your MDS accuracy today determines your compliance and payment stability tomorrow.”
Final Takeaway
Now is the time to treat this as a planned audit event. By proactively reviewing documentation workflows, training your teams, validating your MDS accuracy, and keeping iQIES on your weekly checklist, your facility will be ready when the audit notice arrives. With a potential 2% pay cut on the line, the cost of being unprepared is too high.
