The Skilled Nursing Facility Quality Reporting Program (SNF QRP) is a critical part of how the Centers for Medicare & Medicaid Services (CMS) evaluates the quality of care in nursing homes across the United States. The program helps ensure that skilled nursing facilities (SNFs) meet specific standards of care and report accurate data on the services they provide. This information is then used to assess performance, drive improvements, and ensure transparency for residents and families.

The updates introduce new Social Determinants of Health (SDOH) measures designed to enhance the quality of care by addressing the factors that affect residents’ health and well-being. Additionally, the Centers for Medicare & Medicaid Services (CMS) will update the current transportation SDOH item and initiate a data validation process for SNF QRP submissions starting in the Fiscal Year (FY) 2027.

New Social Determinants of Health (SDOH) Data Collection

Social Determinants of Health (SDOH) are the conditions in which people are born, live, learn, work, play, and age that affect their health outcomes. These include housing, food security, transportation, and access to utilities. The new changes to the Minimum Data Set (MDS), the tool used by SNFs to collect resident data, will focus on better understanding these factors and how they influence the health and well-being of residents.

For residents admitted on or after October 1, 2025, CMS will add four new items under the SDOH category to the MDS. These items are aimed at gathering more detailed information on vital social needs that can affect a resident’s overall health:

  • Living Situation –  This item is about the resident’s living arrangements and whether there are any concerns related to their housing stability.

Example: If a resident has unstable housing or lives in an unsafe environment, this could impact their recovery and quality of life. Addressing this issue early can help SNFs connect patients to community resources to address housing problems.

  • Food Access/Security – There will be two items to assess whether the resident can access sufficient, nutritious food. Food insecurity is a significant health issue for many seniors.

Example: A resident might not have enough food at home or struggle to prepare meals due to mobility issues. Identifying this problem allows the SNF to help by coordinating with local food banks or meal delivery services.

  • Utilities – One item will assess whether the resident has reliable access to essential utilities like electricity, heating, and water, which are critical for maintaining health.

Example: If a resident lives without heat in the winter or has unreliable access to electricity, it can lead to health complications. By identifying these challenges, SNFs can connect residents with necessary services.

These changes are important because by assessing these SDOH factors, SNFs can provide more comprehensive care, support residents’ non-medical needs, and improve discharge planning. If any needs are identified, the SNF can work with the residents, their caregivers, family, and community organizations to address them, promoting better long-term health outcomes.

Transportation Item Modification

Another key update is to the Transportation item under the SDOH category. Transportation is often a barrier for many residents to access healthcare services or get to follow-up appointments, impacting their recovery.

Before FY 2027, transportation data was collected both at admission and discharge. Starting in FY 2027, CMS will make the following modifications:

  • Look-back period – CMS will specify the exact timeframe for assessing if a patient has experienced a lack of reliable transportation. This helps ensure the data is accurate and relevant.
  • Simplified Response Options – The way residents report their transportation needs will be simplified, making it easier for the resident and the SNF staff to complete the assessment accurately.
  • Data Collection at Admission Only – The transportation item must only be collected at admission rather than at admission and discharge. This change will reduce the administrative burden on SNF staff, making it easier to manage data collection.

Example: If a resident is admitted to a SNF and lacks reliable transportation, this will be recorded at admission. The simplified response options will make it easier for residents to report whether they can access reliable transportation for future medical appointments or trips outside the facility.

Validation Process for Data Reporting

Starting in FY 2027, CMS will require all SNFs participating in the SNF QRP to undergo a validation process. This process will ensure the accuracy of the data reported by SNFs.

How does data validation work?

  • Random Selection – About 1,500 SNFs will be randomly chosen for this validation process.
  • Medical Records Review – The selected facilities will be asked to share a small number of medical records to validate their submitted data to CMS.
  • Purpose – This process aims to ensure that the quality data reported by SNFs accurately reflects the care provided to residents. It also helps improve transparency and accountability.

Example: If a SNF reports that it has improved the number of residents with their vaccinations up to 90%, the validation process may involve reviewing a sample of medical records to ensure the data reported is accurate and consistent with the records on file.

Important points to remember:

  • Reporting impact – While the new SDOH items are added in FY 2025, data collection and reporting for these elements will not begin until the FY 2027 SNF QRP. This means that SNFs have a two-year window to prepare for these changes.
  • It is essential to remember that SNFs that do not meet the reporting requirements may face a reduction in their annual payment update. This emphasizes the need for strict adherence to the reporting requirements, as it can directly impact the facility’s financial stability.

Strategies for Improvement:

  • Enhance Staff Training and Awareness – Investing in training programs focused on SDOH can equip staff to understand and assess these factors in residents’ lives.

Example: Facilities could have in-services, training, or seminars led by experts in social determinants of health, helping staff recognize how these elements affect resident health and how to collect relevant data effectively. This approach has been successfully implemented in other SNFs, leading to improved staff awareness and more accurate data collection.

  • Develop Assessment Tools – Creating standardized assessment tools focusing on the new SDOH measures will facilitate consistent data collection.

Example: A facility could develop an assessment form that includes questions about living situations, food access, and transportation, allowing staff to familiarize themselves and gather comprehensive information during routine evaluations.

  • Encourage Community Partnerships – Building partnerships with local organizations can help address SDOH challenges faced by residents. Collaborating with food banks, transportation services, and housing agencies can enhance resource availability for residents.

Example: An SNF could partner with local food banks to establish a meal delivery program for residents who face food challenges, directly addressing one of the new SDOH measures.

  • Implement Data Management Systems – Utilizing electronic health records (EHR) and data management systems can streamline the collection and reporting of SDOH data.

Example: Investing in a robust EHR system that allows for easy entry and retrieval of SDOH data will prepare the facility for future reporting and enhance care coordination.

  • Stay Informed with CMS Guidelines – Regularly reviewing CMS updates and guidelines will help facilities stay ahead of changes and avoid potential penalties for non-compliance.

Example: Designating a staff member or team to monitor the CMS SNF Quality Reporting Program webpage can ensure the facility is continuously informed about new developments and requirements.

The updates to the SNF QRP are changes towards a better understanding of a resident’s health, focusing on the SDOH. By preparing early, enhancing staff training, developing comprehensive assessment tools, fostering community partnerships, and staying informed about CMS guidelines, SNFs can navigate these changes effectively and ultimately improve the quality of care they provide.

These changes are an opportunity for SNFs to improve patient care by focusing on the broader factors that contribute to health, and it will be a more person-centered care approach that goes beyond just medical treatment. For SNFs, it is essential to start preparing for these changes by training staff, understanding the new MDS items, and ensuring that data collection processes are streamlined and accurate.

LW Consulting, Inc. (LWCI) offers a comprehensive range of services that can assist your organization in maintaining compliance, identifying trends, providing education and training,  or conducting documentation and coding audits. For more information, contact LWCI to connect with one of our experts!