What to Do If Your SNF Is Selected for CMS MDS Data Validation
Being selected for MDS data validation can feel stressful, but it’s manageable when your facility has a clear plan. This guide walks SNF leaders and staff through the steps from notification to record submission.
Pre-Validation Readiness: Questions to Ask Now
Even before your SNF is selected, asking the right questions can save time and prevent last-minute challenges:
- Who at your organization has iQIES access?
- How often do they log in and check for notifications?
- What is the backup plan if that person is unavailable?
- Who will be responsible for compiling and submitting requested records?
Important: The 45-day clock starts from the day the notification is delivered in iQIES, not when it is seen. Knowing responsibilities ahead of time ensures your team can respond quickly.
Step 1: Confirm Your Selection in iQIES
- Where to check: MDS 3.0 Provider Preview Reports folder in iQIES
- CMS will not send paper or email notifications (except for record receipt confirmation)
- Assign a responsible staff member to monitor iQIES mid-month
Step 2: Understand the Records Request
If selected, CMS may request:
- Up to 10 resident medical records, submitted in their entirety
- Records tied to MDS-based quality measures
- Submission of 100% of requested records within 45 calendar days
Meeting the 45-day deadline is the requirement to pass. Missing it can result in a 2% SNF QRP Annual Payment Update (APU) penalty.
Step 3: Organize the Records Efficiently
- Identify the residents requested by CMS
- Collect all supporting documentation for each selected record:
- MDS Assessment Type is Admissions (5-Day MDS):
- Skin Assessment at Entry
- Nurses Notes – Entry date to 8 days following entry
- CNA Notes – Entry date through 2 days following entry
- Therapy Notes – Entry date through 2 days following entry
- Functional Assessments – Entry date through 2 days following entry
- Treatment Notes – Entry date through 8 days following entry
- MDS Coordinator Interviews
- MDS Assessment Type is Discharge (PPS End-of-stay):
- Skin Assessments at Entry
- Skin Assessments – Last 7 days of stay
- Wound Care Notes – Last 7 days of stay
- Wound Consultation Visit Notes – Last 7 days of stay
- Nurses Notes – Last 7 days of stay
- CNA Notes – Last 3 days of stay
- Therapy Notes – Last 3 days of stay
- Functional Assessments – Last 3 days of stay
- Treatment Notes – Last 7 days of stay
- MDS Coordinator Interviews
- Nursing notes
- Therapy notes
- Interdisciplinary assessments
- Orders and care plans
- MDS Assessment Type is Admissions (5-Day MDS):
- Organize the records as requested, be sure to read the instructions thoroughly as soon as the request is received.
- Confirm completeness and consistency before submission
Tip: Use a checklist for each record to avoid missing pages or documentation.
Technical Clarification: Remember that SNF QRP and VBP are Medicare Part A quality programs. As a result, the MDS assessments subject to validation are Medicare PPS assessments, specifically:
- The 5-Day PPS assessment (referred to in the Validation Notification as the MDS Assessment Type “Admission”)
- The PPS End of Stay assessment (referred to in the Validation Notification as the MDS Assessment Type “Discharge”)
In many cases, these PPS assessments may have been combined with an OBRA assessment type. It is imperative that the medical records you compile and submit align with the correct MDS Assessment Reference Dates (ARDs).
Validation is not just about what documentation you submit, but whether it supports the specific MDS assessment CMS is reviewing. Alignment with the correct ARD protects your facility and ensures your data is evaluated fairly.
Step 4: Submit and Track Your Records
- Submit all requested medical record documentation through the provided secure portal, the URL to a SNFs secured portal is included in the initial selection notification, along with instructions on how to upload files
- Track submission dates and confirm CMS receipt via iQIES or email
- Save all confirmation receipts as proof the 45-day requirement was met
Pro Tip: Proper tracking protects your facility from unnecessary penalties.
Step 5: Review and Learn From Feedback
- CMS may follow up if documentation does not fully support MDS coding
- Review feedback carefully and adjust internal processes as needed
- Conduct an internal debrief to identify lessons learned for future validation periods
Quick Reference Checklist: After Your SNF Is Selected
☐ Selection notification confirmed in iQIES
☐ Residents requested by CMS identified
☐ All supporting documentation collected and reviewed
☐ Records submitted within 45 days
☐ Confirmation of receipt saved
☐ Internal debrief completed and process improvements noted
Reading this out of proactive curiosity?
If you’re reviewing this article to understand what CMS will be looking for before your SNF is selected, an outside perspective can be especially valuable. Celtic Consulting works with SNFs to review documentation and MDS alignment for QRP and VBP quality measures, helping teams see where current practices are strong, and where small adjustments now can better withstand future CMS scrutiny.
Already received your validation notification?
If your SNF has been selected and you’re reading this to ensure you’re following the right steps, Celtic Consulting can help guide you through the process. We support SNFs with documentation review, and submission readiness, helping teams stay organized, meet deadlines, and move through validation with confidence.
Whether you’re preparing ahead or responding in real time, the right guidance can make this process clearer, calmer, and far more manageable–Start a conversation now.
