MDS Leadership in 2026: Accuracy, Audit Readiness, and Revenue Opportunity

Insights from Scott Heichel, RN, RAC-MT, RAC-CTA, DNS-CT, IPCO, QCP, ICC – Director of Reimbursement and Education, Pathway Health

As CMS increases oversight across skilled nursing, leadership teams must recognize that MDS accuracy is no longer just a clinical documentation issue—it’s a financial and compliance strategy.

With improper Medicare payments tied largely to documentation gaps and coding discrepancies, CMS has intensified reviews through programs such as Comprehensive Error Rate Testing (CERT) and new data validation audits. In fact, insufficient documentation continues to be a primary driver of improper SNF payments, which have exceeded billions annually. At the same time, facilities are now seeing SNF QRP and Value-Based Purchasing (VBP) validation audits roll out nationally, verifying that MDS coding accurately reflects the clinical record used to calculate quality measures. These developments place a renewed spotlight on regulatory expectations such as F641 – Accuracy of Assessments, making leadership oversight of MDS processes essential.

Strong leaders are focusing on three strategies for success.

• Strengthen MDS Accuracy and Documentation Integrity: Prioritize interdisciplinary collaboration to ensure the medical record fully supports MDS coding. With F641 (Accuracy of Assessments) under increased scrutiny and CERT audits accelerating, leaders must ensure documentation clearly supports clinical conditions, services provided, and PDPM drivers. Conduct routine internal reviews and provide ongoing education so the MDS accurately reflects the resident’s clinical picture and withstands audit scrutiny.
• Prepare Proactively for CMS Validation and Audit Requests: CMS has released a new round of SNF QRP and VBP Validation Audit Record Requests in IQIES Provider Preview Reports folders. Leadership teams should confirm points of contact, monitor folders regularly, and begin gathering documentation early. Requested medical records supporting sampled MDS assessments must be submitted by April 12, 2026, making early preparation critical to avoid compliance or payment risks.
• Evaluate Medicare PDPM Rates and Benchmark Performance: Leaders should routinely review their facility’s current Medicare PDPM rate and compare it to state benchmark data to determine whether reimbursement accurately reflects resident acuity. Benchmark outcomes against providers in your state to identify potential gaps in coding or documentation. When opportunities for improvement are identified, seek expert review and targeted education to strengthen coding accuracy and reimbursement outcomes. Benchmark your rate now >

Pathway Health Resources
Tools such as the PDPM Medicare Rate Calculator, along with resources like an MDS Baseline Assessment, Reimbursement Review,  and MDS Toolkit, can help leadership teams identify missed reimbursement opportunities and strengthen overall MDS performance.

Remember: Check your IQIES Provider Preview Reports folder today for validation requests and take time to review your current PDPM Medicare rate using the PDPM Rate Calculator to see how your facility compares to state benchmarks and where improvement opportunities may exist.

We’re Here to Help: Schedule a Call with a Pathway professional to discuss your MDS process goals. Contact us.