The Skilled Nursing Facility Quality Reporting Program (SNF QRP) is an annual program, meaning SNFs must continuously strive to avoid each fiscal year’s two percent SNF QRP data submission penalty for failing to meet the data submission threshold requirement, also known as the annual payment update (APU) requirement, as well as to ensure the accuracy of their SNF QRP quality measures (QMs) for public reporting.

The way that the SNF QRP is set up, SNFs often have to work on two program years simultaneously. This overlap happens because there is a lag of four and one-half months between the close of a reporting quarter and its data submission deadline. For example, providers currently are finalizing calendar fourth-quarter 2018 MDS data to meet the last reporting deadline, for the FY 2020 (Oct. 1, 2019 – Sept. 30, 2020) program year. Since Jan. 1, SNFs also have been submitting calendar 2019 MDS data in preparation for the upcoming reporting deadlines for the FY 2021 (Oct. 1, 2020 – Sept. 30, 2021) submission requirements.

Providers need to understand the timeline of what happens when so they can have systems in place to identify and address potential problems timely. Key points in the timeline are discussed below and pulled together into the chart, “Key Dates Impacting Each Fiscal Year’s APU Payment Determinations,” at the end of this article.