CMS SNF Validation Audit 2025: Are You Ready for the 10-Record Documentation Review?

Fall 2025 is bringing something that no SNF can afford to ignore: CMS is launching the formal Skilled Nursing Facility Validation Audit Program. If you're responsible for MDS 3.0 accuracy, PDPM reimbursement, Section GG coding, or quality reporting, you need to get audit-ready now.

This isn't routine paperwork—it's CMS validating that your MDS coding matches your medical chart documentation. The consequences for noncompliance? A 2% reduction in your Annual Payment Update for FY 2027.

What Is the SNF Validation Audit Program?

CMS established this audit-based program to assess the accuracy of Minimum Data Set (MDS)-based quality measures used in the SNF Value-Based Purchasing (VBP) and Quality Reporting Programs (QRP). The program responds to Section 1888(h)(12) of the Social Security Act, which requires the Secretary to validate SNF quality measures.

Key Details:

• Audit Contractor: Healthcare Management Solutions, LLC (HMS)
• Start Date: Fall 2025 (notifications begin)
• Sample Size: 10 MDS assessment records per selected facility
• Response Time: 45 calendar days from notification
• Selection: Random from all eligible SNFs
• Frequency: Once per fiscal year maximum

Who Gets Audited and When?

Eligibility Requirements:

• SNFs that submitted at least one MDS assessment in the previous calendar year
• SNFs that submitted at least one MDS assessment in the current fiscal year

Timeline:

• Fall 2025: Audit notifications begin
• Notification Method: Through your iQIES MDS 3.0 Provider Preview Reports folder (NOT email)
• Response Deadline: 45 calendar days from notification upload

What Documentation Will Be Required?

When selected, your facility must submit medical chart documentation for 10 specific MDS assessment records. This includes supporting documentation for:

Critical Areas Under Review:

• Section GG functional scoring and supporting therapy notes
• ARD dates and clinical justification
• Diagnoses that align with PDPM clinical categories
• Therapy and nursing documentation
• Quality measure data points

Submission Requirements:

• Format: PDF only (no other formats accepted)
• Naming Convention: CCN_MDS Assessment ID (e.g., 111111_123456789.pdf)
• Security: Secure portal provided in audit notification
• Exclusions: No Social Security numbers, no resident face sheets, no documentation outside requested date range

What Are the Penalties for Noncompliance?

For FY 2025 performance period/FY 2027 program year:

• 2% reduction in Annual Payment Update for SNF QRP
• Noncompliance triggers: Failure to submit requested documentation within 45 days
• Appeal process: 30 days to request reconsideration via [email protected]

How to Access Your Audit Notification

CMS will NOT email notifications. Instead:

1. Log into iQIES at https://iqies.cms.gov/ using your HARP credentials
2. Navigate to Reports → My Reports
3. Open MDS 3.0 Provider Preview Reports folder
4. Locate your audit notification with submission instructions and resident list

Key Steps to Prepare Now

Immediate Actions:

1. Verify iQIES access for key staff members
2. Designate Points of Contact (POCs) for audit notifications
3. Review current MDS documentation practices
4. Ensure Section GG scoring has adequate supporting documentation
5. Validate ARD date accuracy and clinical support

Documentation Best Practices:

• Match MDS coding to chart documentation
• Strengthen therapy documentation for Section GG items
• Ensure diagnoses support PDPM clinical categories
• Document ARD rationale clearly
• Maintain organized, date-specific medical records

How SMK Medical Can Support Your Audit Readiness

At SMK Medical, we're helping facilities prepare for this new reality:

Our SNF Validation Audit Services:

• Mock 10-record audits using CMS methodology
• MDS documentation accuracy reviews
• Section GG and ARD compliance training
• PDPM clinical category validation
• Emergency MDS support within 48 hours
• Audit response preparation and submission support

Why Partner with SMK Medical?

• Proven MDS expertise across all assessment types
• PDPM optimization experience since program launch
• Rapid response capability for urgent needs
• Compliance-focused approach aligned with CMS requirements

You don't need to wait for the audit notification. We'll help you identify gaps, strengthen documentation, and maintain compliance—protecting your reimbursement.

Additional Resources and Support

CMS Help Desk: Starting July 1, 2025

• Email: [email protected]
• Hours: Monday-Friday, 8:00 AM - 6:00 PM ET

Key CMS Resources:

• SNF Quality Reporting Program reconsideration process
• iQIES provider folder access instructions
• Validation audit submission guidelines

The Bottom Line

This validation program represents a fundamental shift in CMS oversight. They're no longer accepting poor documentation or passive compliance—they're checking your work against your charts.

The facilities that succeed will be those that proactively strengthen their documentation practices now, before the audit letter arrives.

Don't wait for your notification. Contact SMK Medical today for a comprehensive audit readiness review.

Ready to Get Audit-Ready?

📞 Call SMK Medical: 313-314-8267

Schedule your free audit readiness consultation and protect your facility's reimbursement.

Tags: SNF validation audit, MDS 3.0 audit, CMS SNF audit 2025, PDPM audit, Section GG documentation, ARD compliance, SNF quality reporting, MDS documentation, skilled nursing audit, Medicare audit 2025