FY 2027 SNF Final Rule: A Practical Look at What CMS Finalized 

CMS has finalized its fiscal year 2027 updates to the Skilled Nursing Facility Prospective Payment System, including changes to Medicare payment rates, the SNF Quality Reporting Program and the SNF Value-Based Purchasing Program. 

The final rule also points to longer-term changes involving MDS submission timelines, all-payer resident data and possible future adjustments to the Patient Driven Payment Model. 

The rule takes effect October 1, 2026. 

As always, Simple continues to monitor regulatory updates like these to help skilled nursing facilities stay informed and prepared. Our goal is to make complex reporting, reimbursement and quality requirements easier for provider teams to understand and act on. 

FY 2027 SNF Payment Rates Will Increase by 2.4% 

CMS finalized a 2.4% update to SNF PPS payment rates for FY 2027. The update reflects a 3.3% SNF market basket increase, reduced by a 0.9 percentage-point productivity adjustment. CMS estimates that the update will increase aggregate Medicare Part A payments to SNFs by approximately $882.74 million. 

The 2.4% figure is a national estimate. The impact on an individual facility may differ based on factors such as wage index, case mix and facility characteristics. 

It is also important to view the payment increase separately from the SNF Value-Based Purchasing Program. CMS estimates that SNF VBP will reduce aggregate payments by approximately $203.60 million in FY 2027, and that reduction is not included in the $882.74 million payment-update estimate. 

For clients using Simple for MDS-related workflows, Simple is also increasing the total number of users from 5 to 9 to help support bandwidth and connection reliability after the transition. 

What this may mean for providers 

Finance, reimbursement and operational teams should review the final rate tables and model the effect of the update at the facility level rather than applying the national percentage uniformly across the organization. 

Facilities should also continue monitoring how their VBP performance and incentive payment multiplier may affect the amount ultimately received. 

CMS Is Removing Two COVID-19 Measures From the SNF QRP

Beginning with the FY 2028 SNF Quality Reporting Program, CMS will remove: 

• COVID-19 Vaccination Coverage Among Healthcare Personnel
• COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date 

CMS estimates that removing the measures will reduce administrative costs to SNFs by approximately $8.3 million annually beginning with the FY 2028 SNF QRP. 

This change does not begin with the FY 2027 QRP, so teams should confirm which reporting periods and submission requirements remain in effect before changing internal workflows. 

SNF QRP Submission Deadlines Will Become Much Shorter 

CMS finalized a significant change to the timeframe for submitting SNF QRP assessment data. 

Beginning with the FY 2029 SNF QRP, the deadline will move from 4.5 months after the end of each quarter to the 15th day of the second month following the quarter. In practical terms, that is approximately 45 days. 

CMS expects the shorter timeframe to reduce the delay between data submission and public reporting while giving facilities earlier access to information that may support quality-improvement efforts. 

What this may mean for providers 

Although implementation is still ahead, the change may require SNFs to complete MDS review, correction and submission activities much sooner. 

Facilities may want to begin evaluating: 

• How quickly assessments move from completion through validation and submission 
• Where late documentation or internal handoffs create delays 
• Whether MDS, quality and compliance teams have a shared calendar for quarterly deadlines 
• How corrections will be identified and resolved within a shorter window 

The new timeline makes accurate, timely workflows increasingly important. Waiting until the deadline approaches may leave less time to investigate discrepancies or complete corrections. 

All-Payer MDS Reporting Will Expand 

CMS finalized a requirement for SNFs to submit MDS data for every resident receiving covered skilled care, regardless of payer. 

The requirement will begin with the FY 2031 SNF QRP. 

CMS stated that the change is intended to provide a more complete picture of SNF quality and better align the SNF QRP with other post-acute care programs that collect data regardless of payer. 

CMS estimates that the expanded requirement will increase annual costs to affected SNFs by approximately $88 million beginning with the FY 2031 SNF QRP. 

What this may mean for providers 

The change could expand the number of residents included in a facility’s QRP-related MDS processes and increase the importance of consistent assessment practices across payer types. 

While implementation is several years away, providers should watch for future CMS guidance addressing technical specifications, assessment requirements, submission procedures and operational expectations. 

SNF VBP Performance Standards and Snapshot Dates Are Changing 

CMS finalized performance standards for the FY 2029 and FY 2030 SNF VBP program years to meet the program’s statutory notice requirements. 

CMS also finalized revisions to the snapshot date for two VBP measures calculated using MDS assessment data. The update is intended to keep the VBP calculation process aligned with the revised SNF QRP submission deadlines and will apply beginning with FY 2027 data. 

What this may mean for providers 

MDS submission accuracy and timing may affect more than one program. As CMS aligns QRP deadlines with VBP data processes, facilities should understand how assessment data flows into both quality reporting and performance-based payment calculations. 

MDS, quality, reimbursement and leadership teams may benefit from reviewing the same performance information together rather than managing QRP and VBP as separate workflows. 

Advance Care Planning Remains a Future Measure Topic 

CMS requested feedback on advance care planning as a possible future SNF QRP measure topic. 

Advance care planning involves ongoing conversations and documentation intended to align care with a resident’s values, preferences and goals if the resident becomes unable to make decisions. CMS summarized the comments it received but did not adopt a new advance care planning measure in this final rule. 

Providers should continue watching future rulemaking before making changes based on a potential measure. 

CMS Continues to Examine PDPM Case-Mix Concerns 

The proposed rule included a request for information on possible changes to PDPM and approaches for addressing case-mix increases that CMS associates with coding changes rather than changes in resident characteristics. 

In the final rule, CMS summarized the feedback received but did not finalize a substantive PDPM methodology change. CMS indicated that comments may inform potential adjustments in future rulemaking. 

What this may mean for providers 

There is no new PDPM case-mix adjustment to implement from this final rule. However, the topic remains active. 

SNFs should continue supporting diagnoses, clinical characteristics and MDS coding with clear documentation. Organizations may also want to monitor case-mix patterns across facilities and investigate changes that cannot be readily connected to differences in resident acuity or services. 

Practical Next Steps for SNF Teams 

The final rule includes changes that begin across several different program years, so a clear implementation calendar will be important. 

Providers should consider: 

1. Modeling the FY 2027 payment impact. Review facility-specific rates, wage index information and potential VBP effects. 
2. Confirming current COVID-19 measure obligations. The measures are being removed beginning with the FY 2028 SNF QRP, not immediately. 
3. Preparing for shorter QRP submission windows. Evaluate how quickly MDS data is completed, reviewed, corrected and submitted. 
4. Planning for all-payer MDS reporting. Begin considering how workflows may need to expand before the FY 2031 SNF QRP. 
5. Connecting QRP and VBP oversight. Make sure teams understand how MDS data may support both reporting and payment-related calculations. 
6. Monitoring future PDPM rulemaking. No case-mix methodology change was finalized, but CMS continues to evaluate the issue. 

Simple will continue monitoring updates 

The FY 2027 final rule provides important direction for payment, quality reporting and value-based purchasing, while also establishing future changes that will require longer-term planning. 

Simple will continue tracking CMS guidance, implementation materials and technical updates related to the final rule and sharing information to help skilled nursing facilities understand what is changing and how it may affect reimbursement, reporting and operational workflows.