Washington, D.C. — A federal proposal that would force nursing homes to run skilled-care assessments on every resident regardless of who’s paying for their stay is drawing sharp pushback from industry experts, who say the agency’s own cost estimate badly understates what operators will actually shoulder.
The Centers for Medicare and Medicaid Services is moving to expand the Skilled Nursing Facility Quality Reporting Program, known as the SNF QRP, so that admission and discharge assessments apply across the board — not just to traditional Medicare Part A stays. CMS has pegged the annual burden at roughly $88 million. Industry analysts say the real number is much higher.
“The CMS proposals are not only a compliance burden, but also an extensive administrative burden, that will take hours away from direct resident care,” Jessie McGill, senior curriculum development specialist at the American Association of Post-Acute Care Nursing, told industry sources. AAPACN’s preliminary analysis suggests the $88 million figure is a “very low estimate.”
A parallel paperwork system
Under the proposal, facilities would have to evaluate whether each resident meets four skilled-care criteria: need for skilled services, daily necessity, inpatient-only SNF appropriateness, and medical need. That’s a tall order when the universe of covered residents balloons to include Medicare Advantage, Veterans Affairs, commercial insurance, Medicaid, managed Medicaid, workers’ compensation, and private pay.
CMS is also drafting two new assessment types under the PPS framework, dubbed the “Other Skilled Care Admission Assessment” and the “Other Skilled Care Discharge Assessment.” In effect, that creates a parallel documentation track for non-Medicare skilled residents.
An AAPACN time study from 2025 found that a stand-alone PPS 5-Day assessment runs about 56.92 minutes on average, with a PPS Discharge assessment averaging 32.93 minutes. Multiply that across a building’s census, and clinical staff could lose more than an hour per resident every day to compliance work, according to the group’s findings.
Tracking with broader CMS scrutiny
The expansion lands as operators are already navigating heavier federal oversight, including the agency’s recent moves on PDPM coding scrutiny and case-mix patterns. Critics argue the cumulative weight of these requirements is squeezing direct care time in a sector that’s still short-staffed.
McGill said unit managers, directors of nursing, bedside nurses, and therapists would all be pulled into daily monitoring on top of the documentation they already file. “If it is not documented, it is considered not done,” she noted.
The rule is bundled into the FY 2027 proposed package, but CMS won’t flip the switch until FY 2031. Comments are due to the agency by June 1.
AAPACN is still drafting recommendations, with a focus on preventing redundant data collection — particularly by leaning on OBRA assessments, which facilities already complete on all residents. “We would like to explore if there are ways to collect this data without adding additional assessments,” McGill said.
For now, operators have a narrow window to weigh in before the comment period closes — and a strong incentive to make their math heard.
