PAWSIC Clinical Insight  ·  August 2026

Everything Is Connected: A Systems View of Skin, Falls, and the Human Condition

The CMS SNF Validation Program is auditing pressure injuries, falls with major injury, and medication management. They are not random bad outcomes. They are the visible endpoint of invisible systems falling out of alignment.

Jeanine Maguire, PhD, MPT, CWS, FCPP, President of PAWSIC by Jeanine Maguire, PhD, MPT, CWS, FCPP 7 min read August 15, 2026
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The Bottom Line

CMS's new SNF Validation Program audits three core measures: pressure injuries, falls with major injury, and medication management. Read individually they look like compliance items. Read together they describe the final common pathway of nearly every systemic failure in human care. The most useful clinical frame is not "risk factor" but reserve: what does this person still have, what has been lost, and what does the environment around them need to look like to support what remains?

Audit Active
The CMS SNF Validation Program launched in early 2026 and is currently reviewing the accuracy of MDS quality data submitted by skilled nursing facilities across the United States, with pressure injuries, falls, and medications as core focus areas.

There is a new federal audit program making its way through skilled nursing facilities across the country right now. The SNF Validation Program, launched by CMS in early 2026, is reviewing the accuracy of quality data submitted by facilities, and three of its core measures are pressure injuries, falls with major injury, and medication management.

On the surface, it reads like another compliance initiative. Another checkbox. Another set of consequences for facilities that do not document correctly.

But if you look more carefully, what CMS has actually done, perhaps without intending to, is identify the final common pathway of almost every systemic failure in human care. Pressure injuries. Falls. Medications gone awry. These are not random bad outcomes. They are the visible endpoint of invisible systems falling out of alignment. And that distinction matters enormously if we ever want to do better than manage consequences after the fact.

The Body as a System

Let's start where all care starts: the individual human.

Imagine the theoretically "perfect" person: exceptional vascularity, intact sensation, full cognition, strength, mobility, ideal nutrition, strong bones, fast reaction time, robust hydration, stable mental health, a healthy heart, and a metabolism humming along without interference. This person could sit at a desk for six hours, lie on the beach all afternoon, or sleep in an awkward position and never develop a pressure injury. They could stand up quickly, navigate a dark hallway, or step off a curb without incident. They would need very few medications, and the ones they took would not fight each other.

That person is the baseline. The full reserve.

Now begin removing pieces of that reserve, one at a time.

How Reserve Depletion Lowers the Threshold for Harm

The same two-hour chair sit produces no injury in a person with full reserve, and a Stage 2 pressure injury in a person whose reserves have been compounded by age, disease, and time.

Baseline (full reserve)95%
+ Aging75%
+ Diabetes / PAD50%
+ Malnutrition28%
+ Cognitive decline12%

Illustrative composite, not a clinical scoring tool. Captures the conceptual reframe of working backwards from outcome to reserve rather than forward from risk factor to intervention.

Poor circulation? The tissue can no longer respond to sustained pressure the way it needs to. Diminished sensation? The body stops sending the signals that prompt repositioning. Malnutrition? The skin loses its resilience. Cognitive decline? The awareness needed to self-protect begins to fade. Remove enough of these reserves, not one but several at once, and the threshold for harm drops dramatically. A two-hour chair sit that would be unremarkable for someone with full reserve becomes a pressure injury waiting to happen for someone whose reserve has been depleted by age, disease, and time.

This reframes everything.

We have long talked about "risk factors" for pressure injuries and falls, as if these are isolated variables we can check off on an assessment tool. But perhaps the more useful frame is reserve. What does this person still have? What has been lost? What remains, and how fragile is it?

Working backwards from outcome to reserve, rather than forward from risk factor to intervention, changes the clinical question. It becomes not "is this person at risk?" but "where has this person's capacity to protect themselves been diminished, and what can we do about that?"

Medications: The Double-Edged Reserve

Enter medications, arguably the most complex variable in the system.

Medications exist, at their best, to restore or compensate for missing reserve. The person whose immune system is attacking itself gets an immunosuppressant. The person whose blood pressure is dangerously elevated gets an antihypertensive. The person whose bones have thinned gets supplementation and treatment. Each medication is, in theory, a prosthetic for a failing internal system.

But every prosthetic has trade-offs.

The immunosuppressant that quiets the autoimmune response also quiets the healing response. The antihypertensive that protects the heart creates orthostatic hypotension, that dizzy, unsteady moment upon standing that turns an ordinary trip to the bathroom into a fall risk. The medication that manages one missing reserve creates a gap somewhere else.

And then there is polypharmacy, the reality of many older adults who are managing multiple chronic conditions simultaneously, each with its own medication, each interacting with the others in ways that are not always predictable and are rarely studied together. Add to this the chaos factor of aging itself: not a disease, but a relentless, compounding diminishment of reserve across nearly every system. Skin thins. Muscle mass decreases. Reaction time slows. The kidneys process medications less efficiently. The brain requires more time to integrate sensory input and produce a corrective movement.

The older adult in a skilled nursing facility is, in many cases, a person managing the convergence of all of these forces at once. Compounding reserve loss. Compounding medications. Compounding consequences.

Pressure injuries. Falls. Adverse medication interactions.

These are not failures of individual nurses or individual physicians. They are the output of an extraordinarily complex system operating under enormous strain.

The External System: Where the Body Lives

Now add the second layer: the environment.

Every body exists somewhere. And where it exists shapes what happens to it as profoundly as any internal biology.

At Home

Failing vision, steps, poor lighting, no grab bars, limited ability to summon help, no "medical Uber" for the person who can no longer safely drive. Independence in an environment that was designed for someone younger and healthier.

Maximum autonomy

Assisted Living

A philosophy of supported independence: preserving autonomy, honoring self-direction, respecting the right to take risks. Beautiful. Also a higher tolerance for the kind of freedom that, for someone with depleted reserve, occasionally ends in a fall.

Balanced

Skilled Nursing

The pendulum swings toward safety: oversight, assistance, protection. The facility that achieves zero falls has almost always achieved it partly through restriction. The facility that honors dignity and movement will have falls. This is a truth about human beings.

Maximum safety

The external system, whether home, assisted living, or nursing home, is not a neutral backdrop. It is an active force shaping outcomes. And like the internal system, it has its own reserves and deficits: staffing ratios, architectural design, care philosophy, technology infrastructure, leadership culture, reimbursement pressures, regulatory constraints.

Every outcome is the result of the system that produced it.

What CMS Is Measuring, And What It Isn't

Back to the SNF Validation Program.

CMS is, wisely, measuring the things that are measurable: whether a fall happened and whether it caused major injury. Whether a pressure injury developed. Whether medications were reviewed and whether problems were followed up on. Whether the data submitted on the MDS actually matches the clinical record.

These are legitimate and important things to measure.

What the Audit Measures

  • Whether a fall occurred
  • Whether the fall caused major injury
  • Whether a pressure injury developed
  • Whether medications were reviewed
  • Whether follow-up occurred
  • Whether MDS data matches the clinical record

What It Cannot Measure

  • The reserve a person arrived with
  • The complexity of comorbidities converging
  • The polypharmacy load and its interactions
  • The architectural and staffing constraints
  • The care philosophy of the building
  • Why outcomes happened, not just that they did

But these measure outputs, not systems. They tell us what happened. They do not tell us why, or what the upstream conditions were that made it likely to happen. A facility with the most complex, most medically fragile population in a region will have more pressure injuries and more falls than a facility with a healthier, less depleted population, not because they are providing worse care, but because they are working with systems under greater strain.

This is not an argument against accountability. It is an argument for honesty about what accountability, alone, can achieve.

A New Conversation

Here is what I am proposing. Not a throwing up of hands. Not a resignation to "this is just how it is." A different conversation.

One that begins with human design, not regulatory compliance.

One that uses skin health and mobility, often the last reserves to go, the final visible signal that internal and external systems have lost their alignment, as the proxy measure we actually care about: not a checkbox, but a window into the whole person and the whole system supporting them.

One that asks, before we build another assessment tool or add another documentation requirement: what does this person need in order to remain whole? What reserves remain? What can we restore? What can we protect? And what does the environment around them need to look like to support that?

We have more knowledge now than we have ever had. We understand wound healing at the cellular level. We understand biomechanics and fall prevention. We understand pharmacokinetics in aging populations. We understand the neuroscience of cognition and the sociology of institutional living. We have data. We have technology. We have people who have spent entire careers in this work.

What we have not yet done is bring all of that knowledge together into a coherent, human-centered system, one designed from the person outward, rather than from the regulation inward.

A Signal Worth Taking Seriously

The SNF Validation Program is, in a sense, a signal. It is CMS saying: the things we are measuring matter. Skin. Falls. Medications. These are proxies for something deeper.

Maybe it is time to take that signal seriously, not just as a compliance challenge, but as an invitation to ask harder questions and build something better.

Because it is all connected. The body and the building. The molecule and the movement. The person and the place. It always has been.

Frequently Asked Questions

What is the CMS SNF Validation Program?
The SNF Validation Program is a federal audit launched by CMS in early 2026 that reviews the accuracy of quality data submitted by skilled nursing facilities. Three of its core measures are pressure injuries, falls with major injury, and medication management, and it checks whether MDS data matches the clinical record.
What is the reserve framework for pressure injuries and falls?
Rather than checking isolated risk factors, the reserve frame asks what capacity a person still has to protect themselves. As age, disease, malnutrition, and cognitive decline deplete that reserve, the threshold for harm drops, so the same two-hour chair sit that is harmless for one person becomes a pressure injury for another.
Why can audits alone not improve pressure injury and fall outcomes?
Audits measure outputs, not systems. They record whether a fall or pressure injury occurred, but not the upstream conditions that made it likely. A facility caring for the most medically fragile, reserve-depleted population will show more events than one with a healthier population, not because it provides worse care, but because it works with systems under greater strain.
Jeanine Maguire

Jeanine Maguire, PhD, MPT, CWS, FCPP

President, Post-Acute Wound & Skin Integrity Council (PAWSIC)

PAWSIC.org is dedicated to advancing wound care, skin health, and the systems that support human dignity in care settings. Views expressed are those of the author.

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References

Peer-reviewed sources supporting the reserve concept, polypharmacy and fall risk, person-centered care, and human-centered healthcare design.

  1. Pressure injury, tissue tolerance, and nutritional reserveMunoz, N., Litchford, M., Cox, J., Nelson, J. L., Nie, A. M., & Delmore, B. (2022). Malnutrition and pressure injury risk in vulnerable populations: Application of the 2019 International Clinical Practice Guideline. Advances in Skin & Wound Care, 35(3), 148–155. https://doi.org/10.1097/01.ASW.0000817416.40994.4a
  2. Nutritional interventions for pressure injuries (Cochrane Review)Langer, G., Wan, C. S., Fink, A., Schwingshackl, L., & Schoberer, D. (2024). Nutritional interventions for preventing and treating pressure ulcers. Cochrane Database of Systematic Reviews, 2, CD003216. https://doi.org/10.1002/14651858.CD003216.pub3
  3. Immunosuppressants and wound healingAppoo, A., Christensen, B. L., & Somayaji, R. (2024). Examining the association between immunosuppressants and wound healing: A narrative review. Advances in Skin & Wound Care, 37(5), 261–267. https://doi.org/10.1097/ASW.0000000000000127
  4. Polypharmacy, anticholinergic burden, and fallsWong, H. L., Weaver, C., Marsh, L., Oo Mon, K., Dapito, J. M., Amin, F. R., Chauhan, R., Mandal, A. K. J., & Missouris, C. G. (2023). Polypharmacy and cumulative anticholinergic burden in older adults hospitalized with falls. Aging Medicine, 6(2), 116–123. https://doi.org/10.1002/agm2.12250
  5. Safety vs. autonomy frameworkMarnfeldt, K., & Wilber, K. (2025). The safety–autonomy grid: A flexible framework for navigating protection and independence for older adults. The Gerontologist, 65(3), gnaf111. https://doi.org/10.1093/geront/gnaf111
  6. Frailty, multimorbidity, and nursing home admissionPadrós-Fluvià, A., Martínez-Laguna, D., & Prieto-Alhambra, D. (2022). Dynamics of multimorbidity and frailty, and their contribution to mortality, nursing home and home care need: A primary care cohort of 1,456,052 ageing people. eClinicalMedicine, 52, 101619. https://doi.org/10.1016/j.eclinm.2022.101619
  7. CDC compendium of effective fall interventionsBurns, E. R., Kakara, R., & Moreland, B. (2022). A CDC compendium of effective fall interventions: What works for community-dwelling older adults (4th ed.). Centers for Disease Control and Prevention, National Center for Injury Prevention and Control.
  8. Human-centered design in healthcareLyles, C. R., Wachter, R. M., & Sarkar, U. (2024). The role of human-centered design in healthcare innovation: A digital health equity case study. Journal of General Internal Medicine, 39, 1159–1163. https://doi.org/10.1007/s11606-023-08535-3
  9. Person-centered care in long-term careCoyne, E., & Mewes, I. (2023). Exploring interrelations between person-centered care and quality of life following a transition into long-term residential care: A meta-ethnography. The Gerontologist, 63(4), 660–673. https://doi.org/10.1093/geront/gnac027

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