CMS SNF MDS Data Validation Begins in 2026: What Providers Need to Know and How to Prepare
CMS has announced the start of the Skilled Nursing Facility (SNF) MDS Data Validation Process, with validation beginning January 1, 2026 and provider notifications issued mid-January 2026.
SNFs will be randomly selected for validation, and notifications will be delivered through iQIES. While selection is not performance-based currently, preparation is critical, particularly because failure to meet submission requirements can result in a 2% SNF QRP Annual Payment Update (APU) penalty.
This article outlines what CMS is validating, where to look in iQIES, what happens if you’re selected, and practical steps SNFs can take now to prepare.
Why CMS Is Implementing SNF MDS Data Validation
CMS is required under Section 1888(h)(12) of the Social Security Act to apply a data validation process to quality measures used in the SNF Value-Based Purchasing (VBP) and Quality Reporting Program (QRP).
In the FY 2024 (CMS-1779-F) and FY 2025 (CMS-1802-F) SNF PPS Final Rules, CMS finalized its plan to validate MDS-based quality measures, beginning with the:
- FY 2027 Program Year
- FY 2025 Performance Period
The goal is to ensure that MDS data submitted by SNFs is accurate, complete, and supported by medical record documentation.
How SNFs Will Be Notified of Selection
The initial SNFs selected for MDS data validation will be notified mid-January 2026 but a provider could be selected at any time within the year. Vigilance is key.
📍 Where to look in iQIES:
Notifications will be uploaded to the MDS 3.0 Provider Preview Reports folder in the Internet Quality Improvement Evaluation System (iQIES). CMS will not send paper notices. Facilities that do not routinely monitor this folder risk missing a critical deadline.
What Happens If Your SNF Is Selected for Validation
If selected, CMS will initiate a medical record request related to MDS-based quality measures.
SNFs should expect the following:
- CMS may request up to 10 resident medical records
- Records must be submitted in their entirety
- Facilities must submit 100% of requested records within 45 calendar days
- CMS will confirm receipt of records via iQIES or email
Why the 45-Day Deadline Matters
Submitting all requested records within 45 days is the requirement to pass the validation process.
Failure to meet this submission threshold, regardless of documentation quality, may result in a 2% SNF QRP APU penalty.
CMS has clarified that only one QRP penalty per fiscal year will be imposed, even if other reporting requirements were also not met. Timeliness and completeness are just as important as accuracy.
What CMS Is Validating
CMS is validating whether the MDS accurately reflects the medical record used to calculate SNF VBP and QRP quality measures.
This includes confirming that:
- MDS coding aligns with nursing, therapy, and interdisciplinary documentation
- Clinical status and care delivery are consistently supported in the record
- Submitted data is defensible and reproducible
Validation is not about changing care practices, it’s about ensuring the data tells the correct story.
3 Practical Steps SNFs Can Take to Prepare Now
1. Align Documentation With MDS Coding
Confirm that the clinical documentation in the medical record clearly supports how the MDS is coded; particularly for items tied to MDS-based QRP and VBP quality measures. Review whether nursing, therapy, and interdisciplinary notes consistently reflect the resident’s status captured on the MDS.
2. Conduct Internal Spot Checks
Review a small sample of recent assessments:
- Compare MDS responses to progress notes and therapy documentation
- Identify inconsistencies, copy-forward issues, or missing clinical support
Small reviews often uncover correctable process gaps.
3. Confirm iQIES Access and Accountability
Ensure:
- Appropriate staff have active iQIES access
- Responsibility for checking the Provider Preview Reports folder is clearly assigned
- CMS notifications are escalated promptly
Early awareness creates more control.
Quick Checklist: Are You Ready for MDS Data Validation?
☐ iQIES access is active and routinely monitored
☐ Staff know where validation notices appear in iQIES
☐ A process exists to compile and submit complete medical records quickly
☐ Leadership understands the 45-day, 100% submission requirement
☐ Documentation consistently supports MDS coding
☐ Confirmation of CMS record receipt is tracked
Final Takeaway for SNF Leaders
CMS MDS data validation raises the stakes around how care is documented and reported, not how care is delivered.
SNFs that stay informed, monitor iQIES, and understand validation requirements are far better positioned to navigate selection without disruption, or avoid unnecessary financial penalties.
This is one of those regulatory moments where being prepared matters more than reacting.
If you’re wondering how your current documentation practices would hold up under CMS MDS data validation, an outside perspective can be especially valuable. Celtic Consulting works with SNFs to review documentation and MDS alignment for QRP and VBP quality measures, identifying strengths and areas where small refinements can make your data more defensible, before validation begins.
