2025 Changes in Medicare Cost Reporting for Nursing Facilities — What Administrators Need to Know
- Michelle Shank

- Oct 9
- 3 min read

Beginning for reporting periods ending on or after September 30, 2025, the Centers for Medicare & Medicaid Services (CMS) is introducing significant changes to Skilled Nursing Facility (SNF) cost report requirements. The longstanding CMS-2540-10 form will be replaced by a new CMS-2540-24 form, marking the first revision in about 15 years. (Forvis Mazars)
Here are the key changes and what they mean for nursing facility administrators — including how mobile x-ray services might be impacted.
What’s Changing
The new CMS-2540-24 cost report form demands more detailed data than prior forms. Facilities will need to report additional breakdowns of expenses and revenue that were not previously required. (Forvis Mazars)
CMS is enhancing its ability to track revenue and expenses tied to Medicare Advantage and Medicaid Managed Care populations, not just traditional Medicare. (CLA Connect)
There is emphasis on data that can support more precise rate setting, possibly including development of an SNF wage index, revising the SNF market basket modeling, and refining program margin calculations. (Forvis Mazars)
Potential Implications for Administrators
Increased administrative burden: Gathering the newly required data will likely take more time and effort. Facilities may need to adjust accounting systems, delegate responsibilities, or invest in training.
Higher visibility into partner services: Because CMS wants more accurate cost and revenue data, services that are contracted or outsourced (like mobile imaging and diagnostics) may be more closely examined. Costs associated with mobile x-ray services might need clearer documentation and justification.
Negotiations & contracts might be affected: With more refined reporting, facilities will have better data to assess actual costs of diagnostic services. This may give administrators more leverage in negotiating rates with mobile service providers.
Opportunity to align operations for efficiency: Since CMS is pushing for more granular cost visibility, facilities that proactively collect, track, and analyze their diagnostic service costs may gain competitive advantage, demonstrate better cost control, and improve financial margins.
What Nursing Homes Should Do Now
Audit your current diagnostic service agreements — ensure contracts with mobile x-ray and other third-party imaging providers clearly delineate costs, travel time, handling, and documentation.
Upgrade accounting & reporting systems to capture more granular data (e.g. distinguishing Medicare Advantage vs traditional Medicare, tracking time/costs per service).
Train staff (billing, accounts, clinical liaisons) on the new requirements so reports submitted under CMS-2540-24 are accurate and complete.
Partner with providers who are transparent about their costs and documentation. Mobile x-ray companies that can supply detailed invoices and support documentation will be more attractive under the new regime.
Why These Changes Matter for Mobile X-ray Providers
For mobile imaging services, these developments suggest that your facility customers will place increased emphasis on transparency, cost detail, and reliability. Providers who adapt now — by sharpening their billing, travel time tracking, and reporting of services — will be better positioned to maintain or win contracts with nursing homes as those homes face tighter scrutiny under the updated Medicare cost reporting rules.
Mobile X-Ray of Louisiana Is Ready
Mobile X-Ray of Louisiana is prepared for these upcoming changes. We provide clear, detailed billing and documentation support to help facilities stay compliant while continuing to deliver fast, reliable diagnostic services at the bedside.
By aligning with partners who understand both the clinical and administrative sides of care, nursing facilities can stay ahead of Medicare requirements while keeping residents safe, comfortable, and well cared for.
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