CMS Releases FY 2027 Skilled Nursing Facility (SNF) PPS Proposed Rule: Key Highlights and What Providers Should Know 

On April 2, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Fiscal Year (FY) 2027 Skilled Nursing Facility Prospective Payment System (SNF PPS) Proposed Rule (CMS-1843-P). As required by statute, CMS updates Medicare payment policies for skilled nursing facilities annually, and this proposed rule outlines important changes to payment rates, quality reporting, value-based purchasing, and data submission requirements that will shape SNF operations in the coming years.  

As always, Simple continues to monitor regulatory updates like these to help skilled nursing facilities stay informed and prepared. 

Below is a high-level overview of the most significant provisions and their potential impact on SNF providers. 

FY 2027 Proposed Payment Rate Update 

CMS proposes a 2.4% net increase in SNF PPS rates for FY 2027. This update reflects: 

• A 3.2% SNF market basket update, reduced by 

• A 0.8% productivity adjustment  

Importantly, these figures do not account for the impact of the SNF Value-Based Purchasing (VBP) or Quality Reporting Program (SNF QRP). 

Skilled Nursing Facility Quality Reporting Program (SNF QRP) 

The SNF QRP remains a pay-for-reporting program, meaning facilities that fail to meet reporting requirements will continue to face a 2% reduction to their Annual Payment Update. 

Reported measures are publicly displayed on Care Compare at Medicare.gov, reinforcing the importance of timely and accurate data submission. 

Proposed Changes to the SNF QRP 

Beginning with the FY 2028 SNF QRP, CMS proposes to: 

Remove Two COVID-19 Measures 

• COVID-19 Vaccination Coverage among Healthcare Personnel  

• COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date  

CMS indicates these measures have served their purpose during the public health emergency and are no longer needed as part of the ongoing SNF QRP. 

Revise Data Submission Deadlines 

Starting with the FY 2029 SNF QRP, CMS proposes shortening the submission timeframe from 4.5 months after the end of each quarter to no later than the 15th day of the second month (1.5 months) after the end of each calendar quarter. 

This change aims to: 

• Reduce public reporting lag by up to three months  

• Ensure consumers and families have more current performance data  

Expand MDS Data Submission Requirements 

CMS also proposes requiring submission of Minimum Data Set (MDS) assessments for all SNF residents receiving covered skilled care, regardless of payer. 

This would align the SNF QRP with other post-acute care programs that already require all-payer data collection and may significantly expand reporting responsibilities for many facilities. 

Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program 

The SNF VBP Program remains a pay-for-performance model, funded by a 2% withhold on Medicare FFS Part A payments. CMS is statutorily required to redistribute 50%–70% of this withhold back to SNFs as incentive payments based on performance. 

Key FY 2027 VBP Proposals 

• CMS is providing estimated performance standards for FY 2029 and FY 2030, meeting advanced notice requirements  

• CMS proposes updating the program’s “snapshot date” for two MDS-based measures to ensure alignment with the newly proposed SNF QRP submission deadlines, beginning with FY 2027 data  

This alignment is intended to reduce administrative complexity and support more consistent program timelines. 

Requests for Information (RFI): Looking Ahead 

Advanced Care Planning (ACP) 

CMS is seeking public feedback on Advanced Care Planning (ACP) as a potential future measure for the SNF QRP. ACP focuses on: 

• Ongoing conversations and documentation  

• Aligning care with a patient’s values, preferences, and goals  

• Ensuring appropriate decision-making if a patient becomes unable to communicate their wishes  

CMS is gathering input on how ACP could be meaningfully measured and reported in the SNF setting. 

PDPM Case Mix Upcoding 

CMS is also requesting feedback on potential updates to the Patient Driven Payment Model (PDPM), particularly regarding: 

• Whether current payment policies reflect modern care practices  

• Observed trends related to case mix upcoding  

• Opportunities to ensure payment accuracy and integrity as patient populations and acuity levels evolve  

This RFI signals CMS’s continued focus on payment accuracy and program sustainability. 

What SNFs Should Do Now 

While this rule is still in the proposed stage, SNF leaders should begin preparing by: 

• Reviewing internal QRP and VBP performance  

• Assessing readiness for expanded MDS reporting, especially across payers  

• Monitoring updates to data submission timelines  

• Considering how advanced care planning practices could be standardized and documented  

• Submitting formal comments to CMS on areas of operational or financial concern  

Additional Resources 

Federal Register – FY 2027 SNF PPS Proposed Rule: 
https://www.federalregister.gov/d/2026-06674 

SNF Value-Based Purchasing Program: 
https://www.cms.gov/medicare/quality/nursing-home-improvement/value-based-purchasing 

SNF Quality Reporting Program: 
https://www.cms.gov/medicare/quality/snf-quality-reporting-program