Date Published
December 16, 2025
Author
Kimberly Marselas
SNF cost reporting changes kick in with long-term pay and regulatory implications
New CMS cost report forms demand more granular payer and staffing data from SNFs. Experts warn accurate submissions will shape future reimbursement policy for years.

Many skilled nursing providers will soon be plunged into one of the most significant data submission changes in recent memory, with cost report season getting underway for the majority of providers who close their fiscal year on Dec. 31.

New Medicare cost report forms and the data the Centers for Medicare & Medicaid Services derives from them are likely to affect individual providers and the entire sector for years to come, a pair of accounting experts said Tuesday.

“The redesigned report places greater emphasis on data that can be verified and tied back to facility operations,” said Marinela Shqina, managing director of reporting and analytics for Zimmet Healthcare Services Group. “As a result, transparency and accountability are very foundational.”

CMS will use the new Patient Driven Payment Model-aligned forms to capture more detail on who patient characteristics determine need and services, and additional levels of detail will help the agency better forecast SNF payment rates and a potential skilled-nursing specific wage index.

“By collecting more granular data, CMS can better analyze provider finances,” Shqina added. “This means today’s cost reports will shape future reimbursement policy and oversight, making the accuracy and consistency of reported data critically important.”

The new CMS-2540-24 captures more specific census, payer and staffing information, as outlined in a Tuesday webinar hosted by Shqina and Zimmet Director of Financial Reporting Lynda Hebbeln.

For one, providers must now break out revenue from Medicare Advantage, Medicare, state managed care plans and other payers, rather than just reporting Medicare, Medicaid and private pay as in years past.

There are also additional areas to report contract or agency labor use and costs, as well as costs for today’s commonly used services such as resident activities, QAPI programs, Part A transportation, IV therapy and more, Shqina said.

‘Not just a form update’

And CMS does plan to use the form to have more clarity about providers’ financial status, inside and outside of the Medicare program. Reporting requirements demand that a balance sheet and a statement of patient revenues and operating expenses be completed in its entirety for acceptance. Those details will also be made publicly available, Hebbeln noted.

With revenue broken out by payer and service type, “it does enhance the margin transparencies,” she said.

“This is not just a form update. We get updates all the time, but this is truly a compliance and operational reset with this new cost reporting form,” Hebbeln added. “Accurate reporting is going to protect our reimbursement, our credibility and our audit outcomes.”

She called on providers to update their business, operations and finance teams now and to ensure that software or manual systems are in play to provide the added data types — especially contract labor and related party elements.

Cost reports are typically due at the end of the fifth month after a provider ends its fiscal year. CMS this year, however, granted a one-time 60-day filing extension for “year-enders” acknowledging an expected “learning curve,” Hebbeln said.

“It’s recommended that this extension be used to validate and reconcile the data that’s being reported,” she said. “And, of course, after this time period, the normal filing deadline will resume.”

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