As of October 2025, CMS has officially removed Section R from the Minimum Data Set (MDS), eliminating four items related to social determinants of health (SDOH), including questions on food security, housing, and utilities. The finalized change, initially unexpected, is influencing how skilled nursing facilities (SNFs) approach discharge planning and resident care coordination, and it is receiving mixed reviews from industry leaders.

On the one hand, the removal of these items will reduce the administrative burden on SNFs. The Centers for Medicare and Medicaid Services (CMS) stated in the Prospective Payment System (PPS) for fiscal year 2026 that eliminating these four areas of inquiry on the MDS could save nearly 31,800 hours of staff time across facilities.

At the same time, the federal agency’s decision has also created confusion and operational challenges. The removed SDOH items were originally intended for inclusion in the SNF Quality Reporting Program (QRP), and their sudden removal has disrupted planning around data reporting and quality measurement initiatives.

“We hope they revisit and relaunch this initiative in the coming year, as SDOH plays a major role in successful outcomes for our residents. Determining the barriers and addressing them will only benefit residents and the communities,” Veronica James, vice president of clinical reimbursement at Health Dimensions Group (HDG), told Skilled Nursing News before the MDS version was finalized. 

And so, while the removal of Section R items reduces the immediate workload, it also introduces uncertainty around quality reporting, future data requirements, and how SNFs should align their systems and staff training with evolving CMS expectations.

Many SNFs had already begun preparing workflows and staff training based on the assumption that these items would remain. CMS has hinted that SDOH data may eventually be collected through interoperable electronic systems, but it has yet to provide specific tools or guidance.

“It seems CMS removed section R without discussing it with the people who it directly impacts, and without waiting for comments or feedback from other interested parties. Most communities have already implemented these additional questions as part of their workflows, so the decision to remove the documentation from the MDS is a concerning one,” James said.

While many providers are unsure about whether they should stop collecting SDOH data or continue in anticipation of future requirements, they are hard pressed to let go of the useful protocols that Section R established for person-centered care.

“I have mixed feelings about the removal of Section R,” Sabrena McCarley, vice president of clinical reimbursement and regulatory affairs at TCM Consulting & Management, told SNN. “I fully agree that data collection should be purposeful – we shouldn’t be collecting data just for the sake of compliance. On the other hand, SDOH are incredibly important to resident outcomes, and removing this section feels like a missed opportunity to standardize how we assess and address these factors across settings.”

TCM directly manages a group of SNFs in Illinois and provides consulting to a variety of chains across the country.

Section R questions still relevant 

The removal of Section R means that health-related social needs won’t impact reporting thresholds for data collection such as the Standardized Patient Assessment Data Elements (SPADES). These data cover cognitive function, mental status, medical conditions, and special treatments. 

However, some experts are advising facilities to still ask questions related to these categories for effective discharge planning, as unmet social needs – like food, housing, or utilities – can lead to rehospitalizations and negatively affect resident outcomes.

“So just because the MDS doesn’t require it, CMS doesn’t require it, doesn’t mean they’re not good questions to ask on admission for your residents who are planning to discharge back home,” said Alicia Cantinieri, managing director of clinical reimbursement and regulatory compliance at Zimmet Healthcare Services Group.

And some parts of Section R survive in the MDS.

The transportation question originally in Section R has been moved to Section A as item A1255. It applies only during a 5-day PPS assessment when the resident’s stay is under one year, Cantionieri noted. The question now asks whether in the past 12 months, the resident has lacked reliable transportation that prevented access to medical care, work, and daily needs. And the responses are now simplified to ‘yes,’ ‘no,’ ‘resident declines,’ or ‘unable to respond.’ Since these responses inherently lack detail, it’s important to follow up for effective discharge planning and person-centered care, Cantinieri said.

As for facilities under TCM’s management, they will continue to incorporate social determinants of health questions into care planning, McCarley said.

“The absence of a formal MDS section hasn’t changed our commitment to addressing SDOH – it’s still critical to providing comprehensive, individualized care,” McCarley said. “During our weekly care coordination meetings – where we review skilled residents, those within their MDS assessment lookback periods, and residents preparing for discharge – we intentionally incorporate discussions around health literacy, language preferences, housing stability, and transportation barriers.”

TCM facilities also assess weight trends, relevant medical diagnoses, and oversight by the dietitian to determine if a resident may benefit from participation in one of TCM’s Supporting Older Adults at Risk (SOAR) life skills programs.

“These discussions are essential to ensuring a truly person-centered and safe discharge plan,” she said.

While Section R would have offered a standardized mechanism for documenting this information, TCM has maintained internal workflows that continue to capture and act on these important factors, McCarley said.

Best practices, person-centered care

That said, any easing of regulatory burdens by CMS is generally welcomed.

“More broadly, I believe this change highlights the need for a comprehensive review and modernization of the MDS as a whole. Over time, the tool has grown in scope and complexity, and we need to ensure that the data we’re collecting truly reflects the needs of today’s SNF residents and supports actionable, person-centered care planning,” said McCarley.

And regardless of whether social determinants of health are formalized as part of compliance, SNF providers expect to continue the queries set forth by Section R.

“As a best practice at Health Dimensions Group, we determined that SDOH questions play a crucial role in our resident’s care. We have implemented these questions into our daily core processes. By adding these proposed questions to our admission, quarterly, and discharge assessments, the appropriate plans of care and discharge plans can be made,” said HDG’s James.