For over a decade, the skilled nursing cost report (Form 2540-10) was a relatively static document. That changed effective September 30, 2025. As we move into the 2026 filing season, facilities and legal counsel must grapple with the new Form 2540-24, a document designed with one goal in mind: radical transparency.

What Has Changed?

The most explosive change for litigation and compliance is the Contract Labor Breakdown. Previously, agency costs were often lumped together, making it difficult to isolate specific spending on direct care versus ancillary services. The new form requires a detailed separation of contract labor hours and costs across all cost centers.

• Why this matters: In liability cases alleging understaffing, plaintiff counsel can now easily compare a facility’s spending on agency staff against their claims of labor shortages. The data is no longer hidden in a general ledger; it is on the face of the federal filing.

Medicare Advantage Visibility

For years, the industry has struggled with the "Other Payer" bucket. The new form finally demands a distinct separation of Medicare Advantage (Part C) and Medicaid Managed Care days and revenue. This provides a clearer picture of a facility's true payer mix and financial stability, which is often a key factor in damages calculations and valuation disputes.

The ECS Perspective

At Expert Consulting Services, LLC, we view this new form not just as a compliance hurdle, but as a new baseline for discovery. The data reported this year will set the standard for financial scrutiny for the next decade.

Are you interpreting this new data correctly in your current cases?

🔗 Need an expert to analyze SNF financial data? Visit us at www.expertconsultingservices.com