SNFs in 2026: Preparing for Audits, Surveys, and Value-Based Care

December 18, 2025

What to Expect from CMS in 2026

As we close out 2025 after a year of regulatory challenges, Skilled Nursing Facilities (SNFs) enter 2026 amid evolving CMS rules, heightened compliance oversight, and continued financial pressures. Staying ahead of regulatory and reimbursement changes is essential for operational success and delivering high-quality care.

Here are 3 key expectations:

1. Heightened Audit and Compliance Oversight

CMS introduced Validation Audits to verify the accuracy of MDS items supporting the Quality Reporting Program (QRP) and Value-Based Purchasing (VBP). Healthcare Management Solutions, LLC will conduct these audits, with up to 1,500 SNFs randomly selected annually.

How to Prepare:

Assign a staff member to monitor the iQIES Provider Preview Report for audit notifications.
Develop a process for retrieving and reviewing requested documentation within the 45-day turnaround.
Cross-check MDS assessments against clinical documentation.
Conduct quarterly MDS mock audits and implement QAPI plans as needed, involving all team members.

2. Survey Focus on April and July 2025 Updates

Recent updates to Section PP of the State Operations Manual require attention to:

F605 – Free from Chemical Restraints
F641 – Accuracy of Assessments
F880 – Infection Prevention and Control

How to Prepare:

Review Section PP updates and guidance thoroughly.
Use Critical Element Pathways for process improvement.
Create QAPI plans to address gaps or discrepancies

3. Continued Focus on Value-Based Care

The Transforming Episode Accountability Model (TEAM) launches January 1, 2026. This mandatory CMS payment model focuses on five surgical procedures and emphasizes coordinated care from surgery through 30 days post-hospitalization, with hospitals bearing financial accountability.

Covered Episodes:

Major replacement of the lower extremity (LEJR)
Surgical hip and femur fracture treatment
Spinal fusion
Coronary artery bypass graft (CABG)
Major bowel procedure

How to Prepare:

Identify if your referring hospitals are among the 741 hospitals in Core-Based Statistical Areas (CBSAs).
Understand your performance metrics.
Engage hospitals proactively to become a preferred SNF partner for these episodes.

As Skilled Nursing Facilities (SNFs) enter 2026, they must strengthen compliance processes, proactively monitor quality metrics, and build strategic partnerships to ensure seamless transitions of care and improved patient outcomes.