Earlier this year, we submitted a comment letter on the proposed rule. With the final rule published, we want to share our recommendations, what CMS decided, and where we'll continue pushing.
On July 29, 2026, CMS issued the final rule for the FY 2027 Skilled Nursing Facility Prospective Payment System (CMS-1843-F). Earlier this year, the LTPAC Health IT Collaborative submitted a detailed comment letter on the proposed rule, drawing on our members’ clinical, technology, and research expertise across skilled nursing, long-term care hospitals, inpatient rehabilitation, home health, hospice, and behavioral health settings. With the final rule now published, we want to share what we recommended, what CMS decided, and where we’ll continue pushing.
CMS asked, through a Request for Information, whether Advance Care Planning (ACP) should become a future quality measure in the SNF Quality Reporting Program. Our answer was a clear yes, with conditions.
Our recommendation: We told CMS that a well-designed ACP measure is the accountability mechanism the SNF sector needs to move advance care planning from a routine admission task to a continuous, resident-centered practice. But we drew a hard line against reintroducing an MDS checkbox. CMS removed an ACP documentation item during the 2.0-to-3.0 transition precisely because it produced a “ceiling effect”, nearly universal “yes” responses that told CMS nothing meaningful. With roughly 4.5 million SNF admissions annually, we calculated that even a one-minute checkbox costs the sector 4.5 million staff-minutes a year for no improvement in care.
Instead, we urged CMS to build an outcomes-based measure: Was a resident with a documented DNR resuscitated without clinical justification? Was someone hospitalized despite a documented preference to remain in place? We also called for aligning any measure with FHIR-based standards, specifically the PACIO Project’s Advance Healthcare Directive Interoperability Implementation Guide, and for parallel regulatory clarifications to 42 CFR Part 483 covering the definition of “Resident Representative,” the scope of advance directives, and QAPI integration, so the measure would be built on solid clinical ground rather than documentation formality.
How CMS responded: Because this began as an RFI rather than a proposed policy, the final rule does not adopt a measure yet. CMS confirms it received our comments and those of others on the ACP concept and will take them under advisement for future rulemaking. We see this as a meaningful, if partial, outcome. We didn’t get a finalized measure, nor did we want one rushed, but critically, CMS did not move forward with a checkbox approach either. The door remains open for the outcomes-based, standards-aligned framework we proposed, and we intend to stay engaged as CMS develops this further.
On two related items in the same rule, the shortened MDS submission deadline (moving to roughly 45 days beginning with the FY 2029 SNF QRP) and the shift toward all-payer MDS submission, CMS is finalizing both proposals as planned. We had asked for a codified data-correction process and FHIR-based standardization across Medicare subcontractors to accompany these changes. Those specific safeguards are not yet reflected in the fact sheet summary, and we’ll be watching closely as implementation guidance develops.
The FY 2027 SNF PPS final rule shows that detailed, technically grounded advocacy continues to shape federal health IT policy, even when the full outcome isn’t a straight line from recommendation to regulation. We kept the door open on an outcomes-focused ACP measure rather than a checkbox, and we’ve identified exactly where our continued engagement is needed most: data-correction safeguards, FHIR-based standardization across Medicare subcontractors, and implementation timelines for the shortened submission deadline and all-payer reporting.
We’ll continue monitoring the Federal Register publication of the final rule and accompanying implementation guides, and we welcome dialogue with CMS as this policy moves into operational reality.
For questions about our comment letter or this final rule, please contact the LTPAC Health IT Collaborative Convener, Michelle Dougherty at:
Read the full comment letter from the download link below
