October 1 is when CMS’s MDS changes take effect, and 2026 is a quieter year than most. There is a new RAI Manual, version 1.20.11, but no new item set. The bigger changes this year come from the FY2027 SNF payment rule and the SNF Quality Reporting Program manual, and some of them don’t start until 2027. Here is what changed, from the source documents.
No new item set this year
CMS posted the final RAI Manual v1.20.11 on September 17, 2026, effective October 1, 2026. CMS’s RAI Manual page still lists the v1.20.1v4 item sets (the ones reissued in September 2025 for the J1900 wording) as current, and no new MDS data specifications were posted for October 2026. What did change for October 1 on the technical side is the PDPM grouper: version 2.5000 supports the FY2027 ICD-10 codes and adds, removes and modifies a number of clinical category and NTA comorbidity mappings. If PDPM classification looks different on a new diagnosis this fall, that is the place to look.
For the item changes that came in October 2025, see what changed in RAI Manual v1.20.1.
The coding change most likely to move a measure: reopened pressure ulcers
Under v1.20.1, a pressure ulcer that was documented on admission, closed, and then reopened at the same stage was still coded as present on admission. v1.20.11 reverses that:
“If a resident has a pressure ulcer/injury that was documented on admission, subsequently closed (i.e., healed), and then opens again, the ulcer/injury should not be coded as “present on admission.””
This matters because the short-stay pressure ulcer measure (Changes in Skin Integrity, S038.02) counts a stay when the discharge assessment shows more ulcers at a stage than were present on admission, item by item: M0300B1 minus M0300B2 greater than zero, and the same for Stages 3 and 4 and the unstageable items. An ulcer that no longer counts as present on admission counts as new.
An example. Resident A is admitted with a Stage 2 pressure ulcer on the sacrum. It heals in the second week. In the fourth week it opens again, still Stage 2. On the discharge assessment, M0300B1 is 1. Under the old rule M0300B2 was also 1, and the stay was not in the measure. Under v1.20.11, M0300B2 is 0, and the stay counts as a new pressure ulcer.
The rest of the manual’s staging guidance still applies: a previously closed pressure ulcer that opens again is reported at its worst stage, unless it is now at a higher stage or unstageable. The practical point is prevention after healing. A healed ulcer on a short-stay resident is now the measure’s risk, not a safe harbor.
Other Section M clarifications
- Putting an advanced wound care dressing or a skin substitute on a pressure ulcer is not surgery, a graft or a flap. The ulcer stays a pressure ulcer, and the care goes in M1200E, Pressure ulcer/injury care, not M1200F.
- Adhesive bandages (Band-Aids, wound closure strips) are not dressings for M1200E, M1200F or M1200I. M1200G already had that rule.
More than one interview in the look-back
If the BIMS or the PHQ-2 to 9 was done more than once in the look-back period, the manual now says which one to use:
“If multiple BIMS are conducted during the look-back period, code the MDS with the BIMS conducted closest to the ARD.”
Section D (page D-7) has the same rule for the resident mood interview. Section C also dropped the parenthetical “preferably the day before or the day of” the ARD from the C0100 instruction. The interview still has to fall in the look-back period.
States and payers can’t change the coding rules
New language at the start of Chapter 3, echoed in Chapters 1 and 2:
“MDS 3.0 (non–Section S) items must be coded according to the CMS item definitions, coding instructions, coding tips, and response options in this manual. State or other payer requirements do not replace, modify, or add to the item definitions, coding instructions, coding tips, or response options specified in this manual.”
States can still require Section S items, and can add federal items to Quarterly or PPS assessments. What they can’t do is tell you to code a federal item differently from the manual.
See your building’s short-stay pressure ulcer rate and the rest of its measures, free.
The smaller changes
| Where | What changed |
|---|---|
| J1800, falls | The steps now separate the first assessment after admission (review from the admission date to the ARD) from the first assessment after a reentry (review from the reentry date, A1600, to the ARD). |
| O0110M1, isolation | The words “acquired by physical contact or airborne or droplet transmission” came out of the pathogen description, including the first of the four conditions for single room isolation. The other three conditions are unchanged. |
| O0390 / O0400, respiratory therapy | Nebulizer treatments and maintenance or preventive incentive spirometry don’t count as respiratory therapy minutes unless the respiratory therapist’s or nurse’s supervision is clinically needed. A worked O0400 example was corrected. |
| A1005 / A1010, ethnicity and race | If the resident was asked less than a year ago, the prior answer may be used. After a year or more, ask again. The interview icon was removed from A1005, A1010, A1110 and A1255. |
| Chapter 2 | New guidance on resident transfers during a disaster or public health emergency. |
| Chapter 6, PDPM | “Depressed” became “depression signs and symptoms” in the nursing component. The score thresholds did not change. |
| P0100 / P0200 | Updated references to the State Operations Manual only. The coding guidance on locked units and alarms is the same. |
The SNF QRP and FY2027 payment rule
The FY2027 SNF PPS final rule (CMS-1843-F) was published July 31, 2026, and takes effect October 1, 2026. Along with a 2.4% rate update, it made four changes that touch MDS reporting:
- O0350 (COVID-19 vaccine) becomes voluntary. For residents discharged on or after October 1, 2026, you no longer have to collect it. The item stays on the form until CMS removes it on October 1, 2027, the earliest date CMS said it could. The measure leaves the SNF QRP starting with FY2028, and the October 2026 Care Compare refresh is the last to show it.
- Shorter submission deadlines, starting in 2027. For assessments with a target date on or after January 1, 2027, the deadline moves from about four and a half months after the quarter to the 15th of the second month.
- MDS on every skilled resident, whatever the payer. Starting with residents admitted on October 1, 2029 (the FY2031 SNF QRP), SNFs must submit admission and discharge MDS data on all residents receiving covered skilled care, not only Original Medicare. There is an exemption where a third-party insurer does not cover the skilled services. CMS described modifying one item and adding three new ones to support it.
- SNF VBP snapshot dates move to line up with the new deadlines, beginning with FY2027 data.
“Effective with the FY 2029 payment determination, data must be submitted by 11:59 p.m. ET on the 15th day of the second month after the end of the calendar quarter. For all data submissions, if the 15th day of the second month falls on a Friday, weekend, or Federal holiday, the data submission deadline is delayed until 11:59 p.m. EST on the next business day.”
| Quarter (by target date) | Target date before Jan 1, 2027 | Target date on or after Jan 1, 2027 |
|---|---|---|
| Q1 (Jan–Mar) | August 15 | May 15 |
| Q2 (Apr–Jun) | November 15 | August 15 |
| Q3 (Jul–Sep) | February 15, next year | November 15 |
| Q4 (Oct–Dec) | May 15, next year | February 15, next year |
The same four dates, each three months sooner. Watch May 2027: the fourth quarter of 2026 (old rule) and the first quarter of 2027 (new rule) are both due May 15, 2027. That is a Saturday, so under the next-business-day rule both close on Monday, May 17. The deadline is also the last day a correction counts toward what CMS publishes, so the window to fix a miscoded assessment is three months shorter from 2027 on.
What’s announced for later
The SNF QRP manual V8.0 says falls with major injury will become a hybrid measure beginning with the January 2028 Care Compare refresh, using MDS, claims and encounter data to find falls with major injury during the SNF stay. CMS says the full details will come in V9.0 of the manual. A September 2026 technical report prepared for CMS also describes adding Medicare Advantage records to the discharge to community measure. Neither changes how you code today. As of late September 2026, CMS has not posted an item set for October 2027.
SuperQM reads each discharge assessment against the wound notes, so a reopened ulcer coded as present on admission shows up before the assessment is submitted.
Sources
- CMS, MDS 3.0 RAI Manual page (v1.20.11 release notes, September 17, 2026)
- Final MDS 3.0 RAI Manual v1.20.11, October 2026, and chapter change tables
- CMS, MDS 3.0 Technical Information (PDPM Grouper V2.5000, September 10, 2026)
- FY 2027 SNF PPS final rule, CMS-1843-F, 91 FR 48588 (July 31, 2026)
- CMS fact sheet, FY 2027 SNF PPS final rule (CMS-1843-F)
- SNF QRP Measure Calculations and Reporting User’s Manual V8.0 (effective October 1, 2026)
