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CMS to Suspend Deadline for SNF Off-Cycle Revalidation

CMS to Suspend Deadline for SNF Off-Cycle Revalidation

 

CMS is expected to announce an indefinite suspension of the submission deadline for the mandatory Medicare provider off-cycle revalidation for Skilled Nursing Facilities. The current reporting deadline of January 1, 2026 will no longer apply while this suspension is in effect.

What is SNF Off-Cycle Revalidation?

SNF off-cycle revalidation is a CMS directed process requiring skilled nursing facilities to resubmit and validate enrollment information in Medicare outside of the standard 5-year revalidation cycle. It is used by CMS to confirm ownership, managing control, practice location, and compliance with Medicare enrollment requirements.

A formal update from CMS with additional details is anticipated soon. HTS will share official guidance and next steps with our partners as soon as it is released.

Thank you for your continued partnership. Please watch for further updates.

 

Written by:

Sheena Mattingly, M.S., CCC-SLP, RAC-CT  |  Executive Vice President of Quality & Compliance, HTS

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Federal Government Shutdown

What Nursing Homes Need to Know

 

On October 1, 2025, a U.S. federal government shutdown was announced. While the news may create uncertainty across healthcare sectors, nursing home operations are expected to continue with minimal immediate impact. The Centers for Medicare & Medicaid Services (CMS) released QSO-26-01-ALL, outlining how nursing homes will be affected during this period.

Here’s What You Need to Know:

Medicare & Medicaid Payments Will Continue
Medicare and Medicaid payments are considered mandatory spending, so funding for these programs will not stop. Nursing homes should continue receiving payments for services rendered.

Administrative Delays Are Likely
Longer wait times and limited access to agency staff should be expected. Due to staffing reductions at CMS, administrators, providers, and beneficiaries may have delays with:

  • Payment processing
  • Waiver approvals
  • Technical assistance requests

Federal Surveys & Certifications Limited
CMS has announced that only the most serious complaint investigations, those related to actual harm, will move forward. Other oversight activities are paused, including:

  • Routine recertification surveys
  • Inspections tied to less serious complaints\
  • Oversight activities of major CMS contractors

This means nursing homes may experience delays in routine compliance checks.

Independent Dispute Resolutions (IDRs) on Hold
No Independent IDRs will be conducted unless tied directly to a serious complaint that could result in immediate adverse action against a facility during the shutdown.

Exception: Revisit Surveys to Prevent Termination
State Survey Agencies (SAs) may request approval to conduct a revisit survey only if:

  1. A provider has alleged compliance with CMS requirements following a determination of noncompliance, and
  2. The revisit survey is necessary to confirm compliance and prevent scheduled Medicare termination, and
  3. The termination is imminent due to timing or specific circumstances.

Residential Surveys Will Continue
Residential surveys and complaint investigations outside of the federal oversight process will continue, ensuring resident care and safety are still being monitored at the state level.

Bottom Line:

While Medicare and Medicaid funding remains secure, nursing homes should prepare for administrative delays and limited federal oversight during the shutdown. Leaders should stay informed, document all compliance efforts, and prepare for longer turnaround times on requests made to CMS.

For details, read the full memo here: QSO-26-01-ALL.

Written by:

Sheena Mattingly, M.S., CCC-SLP, RAC-CT  |  Executive Vice President of Quality & Compliance, HTS

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Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) Spotlights and Announcements

Now available! New Provider Data Catalog makes it easier to search and download publicly reported data. Also, Medicare’s Compare sites have been improved.

Notice of Upcoming SNF QRP Measure Removals – January 2024

The Centers for Medicare & Medicaid Services (CMS) is alerting Skilled Nursing Facility (SNF) providers of upcoming measure removals from the SNF Quality Reporting Program (QRP). The following quality measures are planned for removal from the iQIES Review and Correct Reports, Facility-Level Quality Measure (QM) Reports, and Resident-Level QM Reports in January 2024:

  • Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function
  • Application of IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients
  • Application of IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients

Once removed from reports, users will no longer have access to any data or measure results for these measures.

Click here to read more.

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SNF Provider Preview Reports – Now Available

The Skilled Nursing Facility (SNF) Provider Preview Reports have been updated and are now available. These reports contain provider performance scores for quality measures, which will be published on Care Compare and Provider Data Catalog (PDC) during the January 2024 refresh.

The data contained within the Preview Reports are based on quality assessment data submitted by SNFs from Quarter 2, 2022 through Quarter 1, 2023. Additionally, the Centers for Disease Control and Prevention (CDC) measures reflect data from Quarter 4, 2022 through Quarter 1, 2023 for the Influenza Vaccination Coverage Among Healthcare Personnel measure, and Quarter 1, 2023 for the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure. The data for the claims-based measures will display data from Quarter 4, 2020 through Quarter 3, 2022 for this refresh, and for the SNF Healthcare-Associated Infections (HAI) measure, from Quarter 4, 2021 through Quarter 3, 2022. Providers have until November 13, 2023, to review performance data.

To locate your SNF Provider Preview Reports in iQIES, please follow the instructions listed below:

  1. Log into iQIES at https://iqies.cms.gov/ using your Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) user ID and password. (If you do not have a HARP account, you may register for a HARP ID.)
  2. From the Reports menu, select My Reports.
  3. From the My Reports page, locate your MDS 3.0 Provider Preview Reports folder. Select the MDS 3.0 Provider Preview Reports link to open the folder.
  4. Displayed for you is a list of reports available for download.
  5. Select desired SNF Provider Preview report name link and the report will display.

NOTE: SNF Provider Preview report links are titled “SNF Provider Preview Report”. For questions related to accessing your facility’s provider preview report, reach out to the iQIES Service Center by email iqies@cms.hhs.gov or call 1-800-339-9313. For questions about SNF Quality Reporting Program (QRP) Public Reporting, email SNFQRPPRQuestions@cms.hhs.gov.

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Now Available: Final MDS 3.0 RAI User’s Manual Version 1.18.11

The final Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) User’s Manual version (v)1.18.11 is now available in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page. The MDS 3.0 RAI User’s Manual v1.18.11 will be effective beginning October 01, 2023.

This version of the MDS 3.0 RAI Manual contains substantial revisions related to the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), which requires that standardized assessment items be collected across post-acute care (PAC) settings. Standardized data will enable cross-setting data collection, outcome comparison, exchangeability of data, and comparison of quality within and across PAC settings. Additionally, the language of the manual has been updated throughout to be gender neutral. Guidance and examples in numerous chapters and appendices have been revised for clarification and to reflect current regulations and best practices. Due to the scope of the revisions, CMS will not issue Replacement Pages for v1.18.11; those wishing to continue using a physical copy of the manual are encouraged to print the new version.

A document listing all changes from the MDS 3.0 RAI Manual v1.18.11 draft version to the final version is available for reference in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page.

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Proposed Minimum Staffing Standards for LTC Facilities… What You Need to Know

Blog by: Janine Lehman, RN, RAC-CT, CLNC, Director of Legal Nurse Consulting, Proactive LTC Consulting

The Centers for Medicare & Medicaid Services (CMS) issued the long-awaited Proposed Minimum Staffing Rule on 9/1/23 with the stated objective of seeking “to establish comprehensive nurse staffing requirements to hold nursing homes accountable for providing safe and high-quality care for the over 1.2 million residents receiving care in Medicare and Medicaid certified facilities each day”.

Here’s what you need to know…

This proposed rule consists of three core staffing proposals:

  1. Minimum nurse staff standards of 0.55 hours per resident day (HRPD) for Registered Nurses and 2.45 HPRD for Nurse Aids;
  2. A requirement to have an RN onsite 24 hours a day, seven days a week; and
  3. Enhanced facility assessment requirements.

Click here to continue reading this blog.

 

About Proactive Medical Review
HTS partners with Proactive Medical Review, a third party company who specializes in ensuring compliance with regulatory standards and promoting measurable care excellence. The team includes SNF experienced nurse, MDS, Health Facility Administrator, therapist and reimbursement specialists with experience serving in multi-site contract therapy operations, as corporate directors of quality, clinical program specialists, and Compliance Officers. Proactive is uniquely positioned to assist in managing the many changes and challenges facing providers partnered with HTS. Learn more about our commitment to compliance here.

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CMS Resource: PHQ-2 to 9 Cue Card

CMS is offering a cue card to assist providers in coding the Patient Health Questionnaire (PHQ-2 to 9) as referenced in the coding guidance for D0150. This resource is intended to be utilized during the Patient Mood Interview as a supplemental communication tool that provides a visual reference to assist patient selection of symptom frequency.

The cue card is offered in two sizes which can be viewed or printed and is available in the Downloads section of the HH QRP, IRF QRP, and LTCH QRP Training pages.

Click here to download the Cue Card.

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5-Star Preview Reports Available on 1/23/2023

CMS announced that the Five-Star Preview Reports are available on January 23, 2023.

To access these reports, select the CASPER Reporting link located on the CMS QIES Systems for Providers page. Once in the CASPER Reporting system, select the ‘Folders’ button, then select ‘My Inbox’ or the Inbox beginning with ‘LTC’ and the state abbreviation followed by a facility ID. The reports only remain in the QIES system for a short time, so please save and/or print these reports for your records.

Nursing Home Care Compare will update with the Five Star data on or around January 25, 2023.

Important Note: The 5-Star Help Line (800-839-9290) will be available from January 23 through January 27, 2023. Please direct your inquiries to BetterCare@cms.hhs.gov if the Help Line is not available.

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OIG to Audit Telehealth Services in 2023

CMS has a substantial influence on how telehealth services are delivered and paid. Specifically, CMS sets forth regulation for payment and coverage requirements.

The Office of Inspector General (OIG)’s 2023 Work Plan will provide significant oversight on telehealth services including the impact of PHE flexibilities. The OIG reviews will provide objective findings and recommendations that can further inform providers about telehealth. The oversight intent is to ensure that the potential benefits from telehealth are realized for beneficiaries.

We got you! Here are our top 5 takeaways:

  1. Due to the PHE, actions have been taken to allow practitioners to provide telehealth services.
  2. Telehealth may offer an alternative method for necessary care to be safely delivered to residents in appropriate situations. This flexibility has been extended through CY 2024 and is no longer tied to the end of the federal PHE.
  3. If a beneficiary denies the use of telehealth, services will not be performed via this delivery mode.
  4. Creating an environment for successful telehealth services can make a huge difference in the efficacy of treatment. More guidance can be found here.
  5. Document, document, and then document some more. Proper documentation of the validity of the use of telehealth is imperative. Review entities will be looking for documentation as proof that the “right” steps were taken when performing telehealth (and other) services. Document any interdisciplinary collaboration, beneficiary consent to the delivery mode, the clinical appropriateness of the delivery mode, and that other options for safely delivering services in the direct presence between the resident and staff have been exhausted.

 

Need a Powerful Therapy Partner? Contact Amanda Green, Executive Director of Strategic Development amanda@htstherapy.com for information about our contract therapy partnerships.

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SNF Claims with Zero Hospital Days Prior to Admission Under Review

Blog by: Stacy Baker, OTR/L, RAC-CT, CHC, Proactive Medical Review

Effective July 15, 2022, HHS Secretary extended the PHE, the new expiration date being October 13, 2022. CMS continues to recognize that disruptions arising from a PHE can affect coverage under the SNF benefit:

  • Prevent a patient from having the 3-day inpatient QHS.
  • Disrupt the process of ending patient’s current benefit period and renewing their benefits.

While providers may continue using the QHS and Benefit Period Waivers, documentation needs to support how the skilled stay relates to the PHE, and in the absence of the pandemic, that the skilling condition would have required an inpatient hospital stay.

Going back to the March 13, 2020 letter to HHS from CMS Administrator, “SNF care without a 3-day inpatient hospital stay will be covered for beneficiaries who experience dislocations or are otherwise affected by the emergency, such as those who are (1) evacuated from a nursing home in the emergency area, (2) discharged from a hospital (in the emergency or receiving locations) in order to provide care to more seriously ill patients, or (3) need SNF care as a result of the emergency…” The letter goes on to state that the benefit period waiver “will apply only for those beneficiaries who have been delayed or prevented by the emergency itself…”

Furthermore, Proactive has seen recent medical review activity from the Supplemental Medical Review Contractor (SMRC), Noridian. Their current project reports that data analysis completed by CMS and the SMRC identified a potential area of vulnerability, and the SMRC is tasked to perform a medical review on SNF claims (3/1/2020 – 12/31/2021) that had zero hospital days prior to admission.

Click here to continue reading this blog.

 

About Proactive Medical Review
HTS partners with Proactive Medical Review, a third party company who specializes in ensuring compliance with regulatory standards and promoting measurable care excellence. The team includes SNF experienced nurse, MDS, Health Facility Administrator, therapist and reimbursement specialists with experience serving in multi-site contract therapy operations, as corporate directors of quality, clinical program specialists, and Compliance Officers. Proactive is uniquely positioned to assist in managing the many changes and challenges facing providers partnered with HTS. Learn more about our commitment to compliance here.