08/07/2025

October MDS Changes: What MDS Nurses Need to Know Now Updates from the SNF PPS Final Rule, QRP, and VBP Programs

The release of the FY 2026 SNF PPS Final Rule and accompanying CMS updates has important implications for MDS nurses as they prepare for the October 1, 2025 implementation of MDS 3.0 version 1.20.1. These changes affect data collection, public reporting, and Medicare reimbursement. Below is a summary of the key updates:

MDS 3.0 Updates

CMS is finalizing its proposal to remove four standardized patient assessment data elements from the Minimum Data Set (MDS), the SNF resident assessment form, beginning with residents admitted on or after October 1, 2025. CMS is also finalizing its proposal to amend the reconsideration request policy and process.

Draft MDS 3.0 Item Sets v1.20.1v3 – May 23, 2025

CMS released a revised draft of the MDS item sets (v1.20.1v3), reflecting the removal of Section R. Specifically:

• Items on Living Situation, Food, and Utilities have been removed.
• Item R0340 (Transportation) has been replaced with A1255 (Transportation).
• Final MDS item sets are expected in late summer, pending final rulemaking decisions.

SNF Quality Reporting Program (QRP) Updates

Final Rule CMS-1827-F – July 31, 2025

CMS finalized the removal of four Social Determinants of Health (SDOH) items from the MDS assessment: one Living Situation item, two Food items, and one Utilities item. Other updates include:

• Changes to the reconsideration policy and process.
• Summary of feedback received on three Requests for Information: future quality measures, revised data submission deadlines, and the advancement of digital quality measurement in SNFs.

July 2025 QRP Data Refresh

The July refresh of SNF QRP data is now live on the Medicare Compare Tool and the Provider Data Catalog (PDC).

Non-Compliance Notifications – July 21, 2025

SNFs found to be noncompliant with calendar year 2024 SNF QRP requirements will experience a reduction in their FY 2026 Annual Payment Update. Notifications were posted to providers’ My Reports folders in iQIES. Facilities may submit reconsideration requests to CMS by August 26, 2025. These requests must exclude all protected health information and remain under 20 MB in size.

Provider Preview Reports – July 15, 2025

Updated SNF Provider Preview Reports are available. These contain quality measure scores that will be publicly reported in the October 2025 Compare Tool update.

SNF Value-Based Purchasing (VBP) Updates

Final Rule – August 4, 2025

The final rule introduces several policy updates to the SNF VBP Program for FY 2026 and beyond, including:

• Removal of the Health Equity Adjustment
• A new reconsideration request process for SNFs to appeal review and correction decisions
• Alignment of SNF VBP policies with other CMS quality programs

Performance Score Reports – August 1, 2025

Performance Score Reports for the FY 2026 program year are now available in iQIES. These include each facility’s incentive payment multiplier, which affects Medicare Part A per diem payments starting October 1, 2025.

SNF VBP Measures for FY 2026:

• SNF 30-Day All-Cause Readmission Measure
• SNF Healthcare-Associated Infections Requiring Hospitalization
• Total Nursing Staff Turnover
• Total Nurse Staffing Hours per Resident Day

Correction requests may be submitted until August 31, 2025. Requests must include the SNF’s name, CMS Certification Number (CCN), the correction, and a justification, and be sent to SNFVBPquestions@cms.hhs.gov