The MDS Guru - Episode 85 - The September FAQ for the SNF Validation Program
Sep 13, 2026 · 4 min · 5 segments
Send us Fan Mail What do they want now? A pivotal CMS clarification.
- Speakers
- MelindaHost
- Top entities
- Patient Health Questionnaire×2
Sep 13, 2026 · 4 min · 5 segments
Send us Fan Mail What do they want now? A pivotal CMS clarification.
Wanted to update you on the new FAQ document that has come out for the SNF validation program.
CMS is raising the documentation bar again.
It's no longer enough that the MDS answer was correctly obtained, you know, those interviews, and correctly coded and signed timely.
The medical record must contain the supporting evidence showing how you got there.
I want to break this down a little more.
CMS has simply clarified that stating an MDS value came from an interview observation is not enough.
There has to be some supporting documentation in the medical record.
What is so important about that is if you're doing your BIMS or PHQ 2-9 in your MDS and there's nothing else documented about it or documented about the resident's depression or cognition, then that's where you're going to run into trouble.
You can code it correctly, but the medical record has to prove how you arrived at that answer.
And this is where I think facilities need to change how they're thinking about data validation.
You know, that everything is about, did I code it correctly? Did I do it timely? Did I sign it on time? But interview and observation based items are where I think we need to especially be careful.
You need to have some support in your medical record about these items.
Wanted to update you on the new FAQ document that has come out for the SNF validation program.
CMS is raising the documentation bar again.
It's no longer enough that the MDS answer was correctly obtained, you know, those interviews, and correctly coded and signed timely.
The medical record must contain the supporting evidence showing how you got there.
I want to break this down a little more.
CMS has simply clarified that stating an MDS value came from an interview observation is not enough.
There has to be some supporting documentation in the medical record.
What is so important about that is if you're doing your BIMS or PHQ 2-9 in your MDS and there's nothing else documented about it or documented about the resident's depression or cognition, then that's where you're going to run into trouble.
You can code it correctly, but the medical record has to prove how you arrived at that answer.
And this is where I think facilities need to change how they're thinking about data validation.
You know, that everything is about, did I code it correctly? Did I do it timely? Did I sign it on time? But interview and observation based items are where I think we need to especially be careful.
You need to have some support in your medical record about these items.
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