Section GG: Compliance Burden or Your Biggest Competitive Advantage?

Your aggregated facility level data from section GG is already public. The question is whether you’re going to talk about it or let your competitors control the narrative.

Most skilled nursing operators treat functional outcome data as a compliance checkbox: something to collect, submit to CMS, and file away. Meanwhile, hospital discharge planners are pulling up Care Compare before every placement decision, comparing your mobility scores and discharge-to-community rates against every other facility in their network.

Here’s the strategic reality: If your data is good, staying silent about it is a competitive disadvantage. If your data is weak, silence won’t protect you. It just means you’re not doing anything to fix it.

This article isn’t about what facilities have done. It’s about what the data opportunity actually is and how to build a strategy around it if you’re ready to lead with outcomes instead of amenities.

The Fundamental Shift in Post-Acute Referral Decisions
The referral landscape has changed because the incentives have changed. Hospital discharge planners aren’t just trying to find an available bed anymore. They’re trying to avoid readmissions, satisfy ACO quality metrics, and demonstrate value to payers.

When a case manager is choosing between three facilities, they’re asking:

  • Which one will get this patient functional enough to go home?
  • Which one has the lowest readmission risk for this diagnosis?
  • Which one can I defend if this placement goes wrong?

Your website’s photos of the therapy gym don’t answer these questions. Your Section GG outcomes do.

The facilities that understand this are building referral relationships based on demonstrated performance, not relationship lunches and facility tours. They’re speaking the language of risk-adjusted outcomes, functional improvement trajectories, and discharge disposition rates.

What Section GG Actually Measures (And Why It Matters for Marketing)
Section GG captures 17 functional activities across self-care, mobility, and cognitive function. At admission and discharge, therapists score patients on their level of independence for activities like:

  • Eating and oral hygiene
  • Toileting and personal hygiene
  • Bed mobility and transfers
  • Walking and wheelchair mobility
  • Stairs

The scoring ranges from complete independence to total dependence, creating a quantifiable measure of functional improvement during the SNF stay.

Here’s why this matters for your marketing strategy: These aren’t arbitrary quality measures. They’re the specific functional milestones that determine whether someone can safely discharge home versus need ongoing institutional care.

When you show a discharge planner that 80% of your orthopedic patients improve from “substantial assistance” to “supervision or setup” for transfers, you’re demonstrating exactly what they need to know: You can get patients safe enough to go home.

The Strategic Framework: Four Levels of Outcomes Transparency

Level 1: Internal Baseline (Where Most Facilities Are)
You collect Section GG data, submit it to CMS, and maybe review it quarterly in a quality meeting. Your marketing materials mention “evidence-based therapy” and “personalized care plans” without any performance data.
Your referral sources can see your outcomes on Care Compare, but you’re not helping them interpret it or understand your clinical strengths.

Strategic weakness: You’re letting your data speak for itself with no context, no narrative, and no differentiation.

Level 2: Selective Internal Use
You start using outcomes data in sales conversations. Your liaisons can pull specific statistics for hospital partners: “Our cardiac patients showed X% improvement in mobility scores over the last quarter.”
You’re not publishing anything publicly, but you’re arming your sales team with performance data instead of just capability statements.

Strategic advantage: You’re beginning to speak the language of value-based care, but only with referral sources who ask.

Level 3: Controlled Public Transparency
You identify your clinical strengths (maybe orthopedic outcomes, or cardiac patients, or stroke rehabilitation) and publish high-level performance data on your website and marketing materials.
This might look like:

  • A simple outcomes dashboard showing your performance vs. regional benchmarks for your top diagnosis categories
  • Quarterly “outcomes updates” that you share with referral partners
  • Condition-specific one-sheets that include typical functional improvement ranges for patients like theirs

Strategic advantage: You’re controlling the narrative before case managers look you up on Care Compare. You’re showing confidence in your clinical performance and making it easy for referral sources to justify sending you patients.

Level 4: Full Outcomes-Based Positioning
Your entire value proposition centers on functional outcomes. Your website, your liaison conversations, your ACO partnerships, and your family admission process all lead with data.
You’re not just transparent. You’re using outcomes as your primary differentiator. You update your data regularly, you benchmark against competitors, and you’re clear about which patient populations you excel with.

Strategic advantage: You’ve fundamentally changed the buying criteria. Competitors who can’t or won’t match your transparency are at a structural disadvantage.

How to Build Your Outcomes Marketing Strategy (The Honest Version)

Step 1: Audit Your Current Performance
Before you can market outcomes, you need to know if your outcomes are worth marketing. Pull your last four quarters of Section GG data and compare it to:

  • CMS national benchmarks (available on Care Compare)
  • Your state/regional averages
  • Your own facility trends

Be brutally honest. If you’re below benchmark in most categories, you have a clinical problem that marketing can’t solve.
Identify where you’re actually strong. You don’t need to be top-quartile in everything. Maybe you’re exceptional with joint replacement patients but average with stroke. That’s fine: lead with your strengths.

Step 2: Fix Your Data Integrity First
Most facilities have Section GG scoring inconsistencies that artificially inflate or deflate their outcomes. Common issues:

  • Therapists under-scoring at admission to make discharge improvements look better
  • Inconsistent interpretation of scoring guidelines across staff
  • Missing or incomplete assessments that skew your reported performance

If your data isn’t clean, publishing it will backfire. Case managers who see inflated outcomes will lose trust when they see the actual patient results.

Invest in Section GG training and inter-rater reliability testing before you invest in marketing materials.

Step 3: Develop Your Narrative Framework
Raw data without context doesn’t build trust. It creates confusion. Your outcomes marketing needs a clear narrative structure:

For referral sources: “We specialize in [patient population], and our data shows we consistently achieve [specific functional outcome] for [X%] of these patients, compared to [benchmark]. This means fewer readmissions and faster discharge-to-community for your high-risk cases.”

For families: “Most patients who come to us with [condition] arrive needing [level of assistance] and leave able to [functional milestone]. Here’s what that recovery trajectory typically looks like and how we’ll track progress.”
The narrative makes the data meaningful. It answers the “so what?” question that raw percentages don’t.

Step 4: Start Conservative, Scale Based on Response
Don’t overhaul your entire website on day one. Test outcomes-based messaging with your most sophisticated referral sources first:

  • Add outcomes data to your liaison leave-behinds for hospital partners who are already asking about quality metrics
  • Include functional improvement statistics in your ACO partnership proposals
  • Create a single PDF “outcomes snapshot” that your admissions team can use with families who ask detailed questions

Track the response. If case managers engage more deeply with your data-focused materials, expand. If families respond positively to seeing realistic functional expectations, incorporate it into your standard admission process.

Step 5: Commit to Regular Updates
Outcomes transparency isn’t a one-time project. It’s an ongoing commitment. If you publish quarterly outcomes and then go silent for a year, you’ve actually damaged credibility.
Set a realistic cadence (quarterly is ideal, semi-annual is acceptable) and stick to it. This demonstrates that you’re confident in your sustained performance, not just cherry-picking a good quarter.

The Prerequisites for This Strategy
Let’s be direct about when this approach works and when it doesn’t.

This strategy works if:

  • Your Section GG performance is at or above CMS benchmarks for at least your core patient populations
  • Your data integrity is solid (accurate scoring, complete assessments, consistent interpretation)
  • Your leadership is willing to be transparent about both strengths and areas for improvement
  • You’re prepared to track outcomes long-term and communicate about them regularly

This strategy fails if:

  • You’re trying to hide poor clinical performance behind selective data presentation
  • Your Section GG scoring is inconsistent or gamed
  • You’re not willing to have honest conversations when your data shows weaknesses
  • You view this as a short-term marketing tactic rather than a fundamental positioning shift

You cannot market your way out of poor outcomes. If your data isn’t defensible, your first priority is clinical improvement, not communication strategy.

The Competitive Implications

Here’s what happens when even a few facilities in your market adopt outcomes-based marketing:

For facilities with strong outcomes: You gain a sustainable competitive advantage. Case managers who see your transparent, data-backed performance will preferentially refer to you, especially for complex or high-risk patients. These relationships are sticky. Once you’ve proven yourself with data, competitors can’t easily break in with relationship tactics alone.

For facilities with average outcomes: You face a choice. Either invest in clinical improvement to compete on outcomes, or accept that you’ll increasingly compete on price and availability for less complex patients. The middle ground (decent outcomes but no transparency) becomes the worst position as the market bifurcates.

For facilities with poor outcomes: You’re already losing referrals; you just might not realize it yet. Discharge planners are seeing your Care Compare scores whether you acknowledge them or not. Staying silent doesn’t protect you. It just means you’re not doing anything to improve your position.

What This Really Requires
Building an outcomes-based marketing strategy isn’t primarily a marketing challenge. It’s a clinical culture challenge.
It requires:

Clinical leadership that views transparent performance reporting as a quality improvement tool, not a threat

Therapy teams that understand accurate Section GG scoring directly impacts the facility’s competitive position

Sales and marketing alignment around leading with data instead of deflecting to amenities when outcomes questions arise

Executive commitment to sustained transparency, including communicating honestly when performance dips

If your organization isn’t ready for this cultural shift, that’s a legitimate strategic decision. But understand that you’re choosing to compete on increasingly commoditized factors (location, availability, relationships) while other facilities compete on the one thing that actually matters: demonstrated ability to get patients functional and home safely. 

The Question You Need to Answer
Section GG data is mandatory. The aggregated data is public. It’s already influencing referral decisions.

The only question is whether you’re going to use it strategically or let it be used against you.

If your outcomes are strong, every day you stay silent is a day you’re not differentiating yourself from competitors with weaker performance.

If your outcomes are weak, every day you avoid facing that reality is a day you’re not fixing the underlying clinical issues that are already costing you referrals.

The facilities that will dominate post-acute care over the next five years aren’t the ones with the best lobbies or the longest-tenured liaisons. They’re the ones that figured out how to turn mandatory quality reporting into a trust-building mechanism with the people who control patient flow.

That’s the strategy. Whether you’re ready to execute it is a different question, one only your leadership team can answer.

It’s your data – why not use it? Schedule a 15-minute call.