SNF QRP Requirements: Reporting, Deadlines, and Penalties

Every skilled nursing facility paid under Medicare Part A must comply with the SNF Quality Reporting Program requirements: submit data on 14 quality measures through the correct systems, on quarterly deadlines, and at the required completeness levels. Miss any piece of that and the Centers for Medicare & Medicaid Services (CMS) cuts your Annual Payment Update by 2 percentage points for the applicable fiscal year.¹

Who the Program Applies To

Every SNF paid under the Medicare Prospective Payment System is in the program, regardless of bed count, ownership, or location. There is no opt-out. If your facility accepts Medicare Part A payment for skilled nursing stays, the reporting rules apply.¹

What You Have to Report

CMS currently requires 14 quality measures, and they reach CMS through three different pipelines. The pipeline matters because each has its own submission mechanics and its own compliance threshold.²

MDS Assessment-Based Measures

Nine measures come from the Minimum Data Set (MDS) 3.0 resident assessment. They cover functional outcomes (Discharge Self-Care Score, Discharge Mobility Score, and the combined Discharge Function Score), pressure ulcer and injury rates after admission, falls with major injury among long-stay residents, drug regimen review with follow-up, transfer of health information to the next provider and to the patient at discharge, and the percentage of residents up to date on COVID-19 vaccination (collection began October 1, 2024).²

NHSN Measures

Two measures run on a separate track through the CDC’s National Healthcare Safety Network: COVID-19 vaccination coverage and influenza vaccination coverage among healthcare personnel. Note the boundary: there is currently no QRP requirement to report healthcare-associated infection data through NHSN, which some facilities mistakenly believe is part of the program.³

Claims-Based Measures

Three measures are calculated directly from Medicare fee-for-service claims: Medicare Spending Per Beneficiary, Discharge to Community rate, and Potentially Preventable 30-Day Post-Discharge Readmissions. CMS pulls these automatically, so facilities do not submit anything additional to satisfy them.²

Where and When You Submit

MDS data goes to CMS through the Internet Quality Improvement and Evaluation System (iQIES). NHSN vaccination data goes to the CDC’s system. Submissions run on a quarterly cycle, and data from a given quarter is due roughly four to five months later. For the FY 2027 QRP, covering data collected across 2025, the deadlines are:⁴

Q1 2025 data (Jan 1–Mar 31): due August 18, 2025
Q2 2025 data (Apr 1–Jun 30): due November 17, 2025
Q3 2025 data (Jul 1–Sep 30): due February 17, 2026
Q4 2025 data (Oct 1–Dec 31): due May 18, 2026

When a deadline lands on a weekend or federal holiday, it moves to the next business day. CMS does not grant informal extensions. Running iQIES compliance reports well before each deadline is the reliable way to catch missing data elements while there is still time to fix them.

What “Complete” Actually Means

Filing on time is not the same as complying. The data has to hit two separate thresholds, and both apply.

For MDS assessment-based data, beginning with FY 2026 and every year after, at least 90 percent of the assessments a facility submits must contain 100 percent of the required quality measure data and standardized patient assessment elements.⁵ That is a step up from the 80 percent threshold that applied through the end of 2023.⁶

For NHSN measures, the threshold is 100 percent. Every required reporting period for both staff vaccination measures has to be submitted.³

Both thresholds must be met. A facility at 95 percent on MDS but with a gap in NHSN reporting receives the same penalty as a facility that submitted nothing at all.⁶

What Noncompliance Costs

A facility that fails to meet the reporting requirements takes a 2-percentage-point reduction to its Annual Payment Update for the applicable fiscal year.¹ The APU is the annual adjustment to Medicare payment rates, so the cut compounds across every Medicare claim the facility submits for the entire fiscal year.

Two features make the penalty especially painful. The reduction can push the payment update below zero, meaning per-day reimbursement falls below the prior year’s rate. And the penalty is binary: 89 percent compliance and 10 percent compliance produce the same 2-point reduction. There is no sliding scale.⁶

Challenging a Noncompliance Determination

Facilities that receive a noncompliance letter have 30 days from the date on the notification to submit a reconsideration request. The request must go by email, and CMS will not accept requests submitted late or through any other channel.⁷

Send the request to SNFQRPReconsiderations@cms.hhs.gov with the subject line “SNF QRP Reconsideration Request” followed by the facility’s CMS Certification Number. Include the facility name, address, CCN, the specific reasons for noncompliance identified in the CMS letter, and contact information for the CEO or a designated representative.⁷

Documentation drives the outcome. CMS expects supporting evidence: iQIES submission reports, NHSN submission reports, prior waiver approvals, email records, or a CCN activation letter showing the facility was not yet certified during the reporting quarter. Two hard limits: any file over 20 MB is rejected, and any submission containing protected health information or patient-identifiable data is rejected in its entirety without review.⁷ A screenshot of an MDS assessment with a resident’s name visible kills the appeal.

Disaster Extensions

A separate Exception and Extension (ECE) process covers facilities that could not submit data because of events beyond their control, such as a hurricane, flood, or fire. The request must go in within 90 days of the qualifying event, again to SNFQRPReconsiderations@cms.hhs.gov, with the subject line “Disaster Exception or Extension Request.”⁵

Describe the event, explain its effect on your ability to report, and give a projected date for resuming submissions with a justification for that timeline. CMS acknowledges receipt and responds with a decision by email.⁷

After large-scale disasters, CMS sometimes grants blanket extensions to every facility in identified counties without requiring individual requests, posting a memo that names the counties and quarters covered.⁷ Confirm your facility is actually named in the memo rather than assuming coverage.

Validation and False Claims Exposure

Meeting the deadlines does not close the file. Each fiscal year, CMS randomly selects up to 1,500 SNFs for data validation. For each selected facility, CMS chooses up to 10 MDS assessments and requests the corresponding medical records; the facility has 45 days from the notification in its iQIES Provider Preview Reports folder to respond.⁸ CMS then compares the records against the MDS elements and issues a validation report.

Validation itself does not currently trigger the 2% APU penalty, but the broader legal risk sits behind it. Knowingly submitting false or inaccurate MDS data to obtain Medicare payments can trigger liability under the federal False Claims Act, which carries civil penalties per false claim plus triple damages. The statute does not require proof of intent to defraud; reckless disregard for a claim’s accuracy is enough. Employees who report suspected falsification are protected as whistleblowers and may share in any recovery.

Where the Data Shows Up

Submitted data feeds directly into CMS’s Care Compare tool on Medicare.gov, where families and discharge planners compare facilities side by side. Before data goes public, CMS issues a quarterly Provider Preview Report so facilities can review the numbers and flag errors; corrections appear in the next quarterly release.⁹ Fifteen quality measures also feed the Five-Star Quality Rating System, so QRP accuracy affects star ratings, referrals, and occupancy along with payment.¹⁰

1
Centers for Medicare & Medicaid Services. Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) Overview
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Centers for Medicare & Medicaid Services. Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) Measures and Technical Information
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Centers for Medicare & Medicaid Services. Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) FAQs
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Centers for Medicare & Medicaid Services. SNF QRP Data Collection and Final Submission Deadlines for FY 2027
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eCFR. 42 CFR 413.360 – Requirements Under the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)
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Centers for Medicare & Medicaid Services. SNF QRP Achieving a Full Annual Payment Update (APU) Webinar Questions
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Centers for Medicare & Medicaid Services. Skilled Nursing Facility (SNF) Quality Reporting Reconsideration and Exception and Extension
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Centers for Medicare & Medicaid Services. Overview of the Data Validation Process for the SNF Assessment-Based Measures
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Centers for Medicare & Medicaid Services. Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) Public Reporting
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Centers for Medicare & Medicaid Services. Design for Care Compare Nursing Home Five-Star Quality Rating System Technical Users Guide