Most SNF administrators can tell you within a few minutes where their facility stands on readmissions. It’s muscle memory at this point. Readmissions have been the defining currency of value-based care in skilled nursing for years, and the organizational reflex to monitor them, manage them, and talk about them in every clinical meeting is well-established.
But the rules changed. And a lot of organizations haven’t fully caught up to what that actually means operationally.
Beginning in the FY 2026 program year, the SNF VBP Program is expanding to assess performance on multiple quality measures rather than a single measure of all-cause hospital readmissions. Specifically, the FY 2026 SNF VBP Program now assesses performance on four quality measures: the SNF 30-Day All-Cause Readmission Measure, the Skilled Nursing Facility Healthcare-Associated Infections Requiring Hospitalization measure, the Total Nursing Staff Turnover measure, and the Total Nurse Staffing Hours per Resident Day measure.
Read those last two again. Nursing staff turnover. Total nursing hours per resident day. These are workforce metrics. They live in your HR department, not your MDS office.
Each SNF’s performance score is transformed into an incentive payment multiplier (IPM) using a logistic exchange function, which is then applied to the SNF’s adjusted federal per diem rate for services provided during the applicable program year. That multiplier touches every Medicare Part A claim your facility generates. So when your turnover rate climbs because you lost three CNAs in a quarter and couldn’t hold onto the agency staff who filled in, that’s not just a scheduling headache or a culture problem. It’s a reimbursement problem. CMS withholds 2% of SNFs’ Medicare fee-for-service Part A payments to fund the SNF VBP Program. CMS then redistributes between 50% and 70% of this withhold to SNFs as incentive payments, with the current redistribution set at 60%. The facilities that perform well on these measures get more of that pool back. The ones that don’t, subsidize those that do.
The Structural Disconnect Most Facilities Haven’t Fixed
Here’s where the fresh look comes in. In most SNFs, HR and clinical leadership operate in separate lanes. HR handles hiring, onboarding, benefits administration, and exit interviews. Clinical leadership handles QAPI, care planning, MDS, outcomes management. These two departments share a building but often not a strategy.
That structure made some sense when VBP was solely a readmissions program. Readmissions are a clinical story. But the Total Nursing Staff Turnover measure evaluates the annual turnover rate among eligible SNF staff, including registered nurses, licensed vocational/practical nurses, and nurse aides. And the Total Nursing Hours per Resident Day measure evaluates the average case-mix adjusted total nursing staff hours, including RNs, LPNs, and nurse aides, per resident day. Both of those outcomes are produced by decisions made long before a patient ever arrives at your door. Compensation strategy, onboarding quality, scheduling practices, the culture a unit manager builds on a night shift, whether a new CNA gets a mentor in their first 90 days or gets thrown into the deep end and quits by month two. These are HR and leadership decisions. They now have a direct line to your Medicare rate.
Nursing Staff Turnover is based on Payroll-Based Journal data and captures workforce stability and its impact on care quality. Note what CMS is explicitly signaling there: workforce stability is a care quality indicator. That’s not new thinking from an academic standpoint, but it is new that CMS is willing to tie money to it.
What the Most Adaptive Organizations Are Doing Differently
The facilities that are ahead of this aren’t just tracking turnover as an HR metric. They’re bringing it into clinical governance conversations. The HR Director sits in the QAPI meeting. Turnover trends by unit, by shift, by tenure cohort get reviewed the same way readmission rates and infection data do. When a particular unit shows rising turnover, the question asked isn’t just “who do we need to hire?” It’s “what is happening here clinically, culturally, and operationally that is producing this outcome, and how does it connect to the resident outcomes we’re accountable for under VBP?”
That’s a fundamentally different conversation than what most facilities are having, and it requires a fundamentally different structure. It means HR leadership needs enough clinical context to connect their workforce data to quality outcomes. It means clinical leadership needs to understand that a 40% annual CNA turnover rate isn’t just a staffing nuisance but is potentially pulling down the same performance score as a spike in 30-day readmissions.
One of the notable changes in the FY 2026 scoring methodology is the combination of multiple measure scores to calculate an overall performance score for each SNF. This score, out of 100 points, determines the incentive payment multiplier that will be applied prospectively to SNF Medicare Fee-for-Service Part A claims throughout fiscal year 2026. That composite structure means a weakness in any one measure domain pulls down the whole number. You can run a tight readmissions program and still come out behind because your HR practices are producing a revolving door on the CNA floor.
This Is Not a Compliance Exercise
The temptation for organizations is to approach new VBP measures the way they approach survey preparation: figure out what CMS is looking for, create documentation that reflects it, and move on. That approach will fall apart here. The nursing staff turnover measure is calculated using Payroll-Based Journal data. The turnover measure includes individuals who worked at least 120 hours, and both regular employees and agency staff are included in the turnover measure if they worked sufficient hours to be eligible. CMS is pulling this directly from your PBJ submissions. There is no narrative to offer, no documentation that softens the number. The data is the data.
The only path to performing well on these measures is actually reducing turnover and maintaining adequate staffing hours, which means treating retention as a strategic and financial priority rather than an operational annoyance. That shift doesn’t happen through a memo. It happens when the organizational chart reflects the reality that workforce stability is now a revenue function. When HR has a seat at the table in quality conversations. When turnover is budgeted against its true cost, including the VBP multiplier effect, not just the cost-per-hire calculation that most finance teams are used to seeing.
The focus shouldn’t be on whether your facility knows about the FY 2026 VBP expansion. Most do at this point. The real attention should be given to whether anything has actually changed about how you run the place because of it. If your HR Director is still working in a silo from your quality team, the answer is probably not yet. And that gap is now showing up in your Medicare reimbursement.
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