As 2025 draws to a close, skilled nursing facility operators face a consequential regulatory calendar in 2026. While the repeal of federal staffing mandates removes one compliance burden, numerous other requirements demand attention. Here is a comprehensive guide to the key regulatory deadlines and policy changes on the horizon.
Q1 2026: Ownership Reporting Updates
Effective January 1, 2026, CMS has revised ownership disclosure requirements under the Medicare conditions of participation. Facilities must now report ownership interests of 5% or greater, down from the previous 25% threshold. Related-party transactions exceeding $10,000 annually must also be disclosed. While these requirements fall short of the comprehensive transparency legislation pending in Congress, they represent a significant expansion of reporting obligations.
Operators should review their ownership structures and identify all reportable interests before the March 31 deadline for submitting updated information to CMS. Facilities with complex ownership arrangements involving management companies, property entities, or investor groups will need particular attention.
Q2 2026: Quality Measure Revisions
April 1 brings changes to the quality measures reported on CMS Care Compare and used in the Five-Star Quality Rating System. CMS is adding a new measure tracking antipsychotic medication use in long-stay residents without a qualifying diagnosis, replacing the current measure that excludes residents with schizophrenia or Huntington’s disease from the denominator.
The agency is also introducing a new short-stay measure for functional improvement in mobility, reflecting the sector’s increasing focus on rehabilitation outcomes. Facilities should review their therapy programs and documentation practices to ensure accurate capture of functional gains.
Q3 2026: Survey Process Changes
CMS is implementing a revised Life Safety Code survey protocol beginning July 1, though the scope of changes has been scaled back following pushback from state survey agencies. The revised protocol integrates fire safety and emergency preparedness elements into the standard health survey rather than conducting separate LSC inspections. Facilities should ensure their emergency preparedness plans are current and that staff are prepared to address LSC questions during any survey.
The survey interval is also changing from 15 months to 12 months maximum, meaning facilities will face more frequent inspections. States with surveyor shortages have been granted transitional flexibility, but most facilities should anticipate surveys at least annually beginning in Q3.
Q4 2026: PDPM Updates
October 1 marks the start of FY2027 and the implementation of revised PDPM case-mix weights. CMS has finalized 34 changes to ICD-10 code mappings that affect primary diagnosis classification, potentially shifting reimbursement for certain patient populations. Facilities should model the impact of the coding changes on their typical patient mix and adjust clinical documentation practices accordingly.
The FY2027 payment update is projected at 2.6%, below recent years’ increases, reflecting a lower market basket forecast and productivity adjustment. Combined with the PDPM recalibrations, some facilities may see flat or declining per-diem rates depending on patient mix.
Ongoing: Value-Based Purchasing
The SNF Value-Based Purchasing program continues with an increased withhold percentage of 4% in FY2026, up from 3% in FY2025. The program redistributes withheld payments based on hospital readmission rates, rewarding facilities with below-average readmissions and penalizing those above average. Top-quartile performers can earn back up to 5.1% of their Medicare revenue, while bottom-quartile facilities may lose the full 4% withhold plus additional penalties.
Operators should review their readmission data and implement targeted interventions for high-risk patient populations. Care transitions programs, medication reconciliation protocols, and post-discharge follow-up calls have demonstrated effectiveness in reducing avoidable readmissions.