On July 29, the Centers for Medicare and Medicaid Services (CMS) issued the fiscal year (FY) 2027 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule (CMS-1843-F), which will take effect on October 1, 2026.
In this SNF Final Rule, CMS updated the payment rates used under the SNF PPS for FY 2027, made changes to the SNF Quality Reporting Program (QRP), including removing two measures on COVID-19 vaccine coverage, finalized the requirement to submit MDS for all payers, made changes to the SNF Value-Based Purchasing (VBP) Program, and summarized comments received on the Case-mix creep RFI.
CMS finalized a SNF PPS payment increase of 2.4% for FY 2027, which equates to an increase in aggregate Medicare Part A payments to SNFs of $882 million in FY 2027. This increase is based on a 3.3 percent market basket update, offset by a -0.9 percent multifactor productivity (MFP) adjustment. These financial impacts do not include SNF Value-Based Purchasing reductions, which are estimated to be $208.4 million in FY 2027.
CMS summarized the comments it received on the RFI it issued on case mix creep. CMS is developing a regression framework to quantify the extent to which case-mix trends it is seeing in its data may reflect "case-mix creep." CMS says that their data is showing significant increases in certain case-mix indexes (CMIs) that they feel are unlikely to reflect underlying health status trends in the patient population. CMS provided a methodology overview which is very similar to what was provided in the Proposed Rule.
For FY 2027, CMS did not identify any substantive changes to the PDPM ICD-10 code mappings. They did identify non-substantive updates, which do not alter policy or payment methodology.
CMS finalized removal of two measures from the SNF QRP, specifically the COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure and the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure beginning with the FY 2028 SNF QRP. CMS also finalized that beginning with residents discharged on or after October 1, 2026, SNFs would no longer be required to collect and submit the Patient/Resident COVID-19 Vaccine measure data to CMS.
CMS finalized revisions to the SNF QRP Data Submission Deadlines beginning in FY 2029 from 4.5 months to 1.5 months (roughly 45 days). SNFs must complete their data submissions and make corrections to their MDS assessment data no later than the 15th day of the second month after the end of the calendar quarter. CMS also finalized that SNFs must complete their data submissions and make corrections to their CDC NHSN data no later than the 15th day of the second month after the end of the calendar quarter, beginning with the FY 2029 SNF QRP.
CMS finalized a requirement for MDS data submission on each resident receiving covered skilled care in a SNF, regardless of payer, beginning with the FY 2031 SNF QRP. SNFs will be required to submit these data for all SNF residents, regardless of payer, beginning with residents admitted on October 1, 2029, for purposes of the FY 2031 SNF QRP. Starting in CY 2030, SNFs would be required to submit data for the entire calendar year beginning with the FY 2032 SNF QRP.
CMS finalized updates to the “snapshot date” definition for the DC Function and Falls with Major Injury (Long-Stay) measures beginning with data collected in FY 2027 to maintain alignment with the now finalized SNF QRP submission deadline for MDS assessment data.
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