Beyond the Chart: How CMS Is Validating SNF MDS Data in 2026
CMS has launched a new SNF Data Validation Process to verify the accuracy of quality measure data derived from the Minimum Data Set (MDS) used in both the Skilled Nursing Facility Quality Reporting Program (QRP) and the SNF Value-Based Purchasing (VBP) Program. This is not the typical admission-to-discharge audit many providers are used to. Instead, it targets specific MDS assessment timeframes tied to quality measures and clinical documentation.
How This Differs from Traditional Audits
- The data validation process does not review full admissions through discharge charts.
- CMS selects a small number of MDS assessments per facility (up to 10) to validate specific elements that drive quality measures (e.g., functional status, pressure injuries, falls, infections).
- The focus is on accuracy of MDS coding, and documentation must support the specific date ranges identified in the selection notification.
Selection and Notification
- CMS randomly selects eligible SNFs (those that submitted at least one MDS assessment in the relevant timeframe) on a rolling basis throughout the year. SNFs can only be selected once within a fiscal year.
- Notifications are posted in the iQIES MDS 3.0 Provider Preview Reports folder and will be clearly labeled (e.g., Initial Selection Notification, Second Selection Notification). Some providers have already received notification.
- Providers must actively monitor their iQIES folders; these notices are not broadly emailed.
Documentation Submission: Key Rules
Required Format
- All requested documentation must be submitted in PDF format.
- No other formats will be accepted.
Exact Naming Convention
CMS requires a strict naming convention for each PDF submission: CCN_ValidationID.pdf
Where:
- CCN = the six-digit CMS Certification Number assigned to the facility.
- Validation ID = the unique identifier CMS uses for that specific sampled assessment.
Example: A facility with CCN 111111 and a sample ID 1234 should submit: 111111_1234.pdf
This helps CMS track files precisely and reduces processing delays.
Timeframe for Records
- Only include documentation within the date range specified in the selection notice.
- Do not include unrelated records outside the targeted assessment window.
What Not to Include
To protect resident privacy and meet CMS guidelines:
❌ No Social Security Numbers
❌ No resident face sheets or unnecessary identifiers
❌ No documentation outside the requested date range
CMS explicitly states that submitted files should not contain resident SSNs or face sheets, and should be limited to what is necessary to support the MDS data elements under review.
Security and Submission Logistics
All files are stored in a secure CMS environment with encryption and access controls.
- Requested medical records are uploaded through a secure CMS portal.
- Providers receive automated email confirmations when files are uploaded successfully.
- A second email confirms when all documents have been verified as submitted.
Deadlines and Compliance
- Once selected, SNFs have 45 calendar days to submit all required documentation.
- Failure to respond within this timeframe can result in noncompliance, potentially triggering a 2% reduction in Medicare Annual Payment Update for the applicable QRP/VBP year. Noncompliance is measured by response, not the results of the audit.
Your Power Points
- This process is for data validation, not a full chart audit.
- Documentation must be PDF only with a strict naming convention.
- Only include records for the requested date ranges. Do not include extra files, SSNs, or face sheets.
- Check iQIES regularly for selection notices and deadlines.
For more information: Skilled Nursing Facility Validation Program: Frequently Asked Questions
Being prepared now with processes for naming, compiling, and submitting MDS-related documentation will help you stay compliant, protect reimbursement, and support accurate quality reporting.
Written By: Sheena Mattingly, EVP of Quality & Compliance
