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CMS-2540 cost-report form transition

CMS issued Form CMS-2540-24 as the successor to the long-running CMS-2540-10, effective for SNF cost- reporting periods ending on or after 9/30/2025. It is the first major overhaul of the SNF cost report in nearly 15 years. SNF Shark ingests both forms. The Financial tab on any facility shows whichever form CMS holds for each fiscal year, transparently tagged with a small 2540-10 or 2540-24 pill in the FY column header.

The 9/30/2025 cutover

The trigger is the fiscal-year-end date, not the filing date. A facility on a calendar fiscal year (FY-end 12/31/2025) and a facility on a June fiscal year (FY-end 6/30/2025) end up on different forms for the same calendar-year filing window: the first files on 2540-24, the second still on 2540-10. The transition will therefore be staggered across SNF Shark's data for roughly two fiscal cycles before 2540-24 is universal.

2540-24 also makes electronic filing via MCReF mandatory. That has a knock-on effect on data freshness: CMS's republish cadence on the SNF24FY zips is materially faster than it was for paper- assisted SNF10 cycles. Expect 2540-24 reports to appear in SNF Shark within weeks of submission rather than the months historically common for late-cycle 2540-10 filings.

What 2540-24 unlocks

Six categories of signal that did not exist on 2540-10 are now surfaced in the Financial tab and rollups for any facility filing on the new form:

  • Medicare FFS vs. Medicare Advantage breakout and the mirror Medicaid FFS vs. Medicaid MCO split — visible in the Census & Payor Mix card when the "Split FFS / MA" toggle is on (the default for 2540-24 facilities). MA penetration is one of the strongest leading indicators of margin compression in the sector; the new form makes it directly measurable for the first time.
  • Contract-labor grand total — Wkst A column 4 ("Contract Labor Cost" column added on 2540-24) summed at line 10000. Surfaced as a % of total operating expenses on the Labor Composition card and as a sortable column on chain / portfolio rollup tables. Distinct from agency- nursing comp (Wkst S-3 Pt V), which is contract dollars by job category only.
  • "Paid Claims Verified Current As Of" per- report data-vintage stamp — Wkst S-2 L55/L56 col 2. Tells you exactly how current the claims data backing each report is. Renders as a small cyan badge under the report-status pill on affected FY columns.
  • Granular cost centers: QA & Performance Improvement (L01500), Intravenous Therapy (L03300), and Preventive Vaccines (L08000) are now standard cost centers rather than facility-discretion subscripts. Surfaced as a cyan stripe in the operating-expense mix bar.
  • MCReF filing channel — captured but not currently surfaced; available as a data-confidence cue in future work.
  • Expanded affiliated-transaction detail — Wkst A-8-1 now carries a dedicated "Type" column distinguishing management fees, home-office allocations, real-estate rentals, and other related-party flows that were previously co-mingled.

Why some series step-change at FY2025

Series that span the 9/30/2025 boundary may show a visible discontinuity for one of two reasons:

  1. The new form actually measures something different. For example, "Medicare patient days" on a 2540-10 facility is FFS plus Medicare Advantage combined. On a 2540-24 facility the totals column still carries the same sum, but you can now also see the MA-only portion in its own column. If you flip the payer-mix toggle to "Split", a 2025+ FY column gains a sub-row that earlier years do not have. That is not a data error — it is the new form making a previously-invisible distinction visible.
  2. Some signals don't exist on the old form at all. Contract-labor grand total, the data-vintage stamp, and the new standard cost centers (QAPI, IV, vaccines) have no 2540-10 equivalent. Affected columns and rollup cells show — for pre-2540-24 years rather than zero, so an underwriter doesn't mistake an absent signal for a measured zero.

What stays comparable across forms

The bulk of the Financial tab — income statement, balance sheet, payer-mix totals, occupancy, total-Medicare and total-Medicaid days, per-cost-center expense buckets — uses fields that CMS preserved across the form transition. Where the underlying worksheet coordinates shifted, the pipeline transformer maps both forms into the same column on the CostReport table so downstream queries don't need to branch on form version. Concretely:

  • Net income, total operating expenses, gross / net patient revenue, contractual allowances
  • Total Medicare and total Medicaid patient days (the 2540-24 splits live alongside, not in place of, the totals)
  • Balance-sheet aggregates: total assets, total liabilities, fund balance, current assets, fixed assets
  • Labor: direct-employee salaries by Wkst A cost center, paid hours by S-3 Pt II/III/V
  • Management fees and related-party transaction dollars from Wkst A-8-1

Multi-year comparisons of these fields are safe to read across the form transition.

How to read mixed-form dashboards

  • Form-version pill. Every FY column header on the Financial tab carries a small 2540-10 / 2540-24 pill. Use it as the at-a-glance cue for which baseline the numbers in that column are measured against.
  • Vintage badge. A "Paid claims thru {date}" line under the report-status pill is a direct trust signal — the closer that date is to the FY end, the less likely the numbers are to restate when CMS settles the report.
  • Payer-mix split toggle. Use it when comparing facilities with different Medicare-Advantage exposure; collapse back to legacy when comparing 2540-24 facilities against pre-2024 history.
  • "—" vs "0". A dash means the field doesn't exist on the form for that fiscal year. A zero means the facility reported zero. The distinction is load-bearing for contract-labor and 2540-24-only cost-center cells.