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 Time to Toss the Old MDS-RAI Manuals and Prevent Revenue Losses

 

 

Before there were GPS apps on nearly every mobile phone and installed in the dashboard of many of today’s cars, did you have an old road atlas sitting in your car’s glove compartment? Would you occasionally pull it out to get directions to an unfamiliar address only to get lost because they built a new highway along the route since you bought your atlas 10 years ago?

Do you still refer to a dusty 2011 version of the minimum data set resident assessment instrument (MDS-RAI) manual to refer to or train staff with? If you do, you may experience the same frustration starting on Oct. 1, 2019, when the Centers for Medicare & Medicaid Services (CMS) implements the new skilled nursing facility Medicare Part A prospective payment system (SNF PPS), known as the patient-driven payment model (PDPM).

However, instead of just getting lost, you may lose revenue. This is because the engine that drives the PDPM payment rates is resident characteristics as represented by 188 MDS-RAI data elements.
Under the PDPM, the payment rates for five independently determined component per-diem rates for physical and occupational therapy, speech-language pathology, nursing, and non-therapy ancillary services are determined by the timely and accurate assessment and coding of these items. Many of these items also overlap with items also used in the SNF quality reporting program (SNF QRP).

To implement PDPM, and to standardize the reporting of many resident assessment items across post-acute provider settings, CMS introduced major changes to the MDS-RAI manual that providers should review and retrain staff on prior to Oct. 1.

For example, Chapter 6 of the MDS-RAI manual was replaced in its entirely due to the change from the resource utilization groups, version 4 (RUG-IV) model to the PDPM payment system. This chapter describes how payment rates are established, changes to Health Insurance Prospective Payment System (HIPPS) billing codes, the new interrupted stay policy, and how to address late and missed SNF PPS assessments.

Chapter 2 of the MDS-RAI manual was also substantially altered as CMS eliminated the PPS 14-, 30-, 60-, and 90-day scheduled assessments, as well as the unscheduled other Medicare-required assessments (OMRA) used to report changes in therapy service delivery.

Chapter 2 also provides details about two new assessments: the SNF PPS optional interim payment assessment (IPA) that can be used to change the resident classification and payment rates during a Part A stay, as well as the new optional state assessment (OSA) that some states may use for Medicaid payment purposes. Neither the IPA nor the OSA can be combined with the Omnibus Budget Reconciliation Act of 1987 assessments. 

CMS also added, removed, or changed many specific MDS items described in the MDS-RAI manual. Changes to pay attention to related to PDPM implementation include: A0300—Optional State Assessment (OSA); A0310—Type of Assessment; GG0100—Prior Functioning: Everyday Activities; GG0110—Prior Device Use; GG0130—Self-Care; GG0170—Mobility; GG01305—Interim Performance; I0020/I0020B—Resident’s Primary Medical Condition; J2100—Recent Surgery Requiring Active SNF Care; J2300-J5000—Surgical Procedures; O0425—Part A Therapies; O0430—Distinct Calendar Days of Part A Therapy; Z0100—Medicare Part A Billing; and Z0200—State Medicaid Billing.

Providers can download and print the most recent version of the MDS 3.0 RAI Manual (currently v1.17 October 2019 at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html). CMS has indicated that this manual may be updated again prior to October.

CMS has also developed substantial provider training related to these changes to the MDS-RAI manual that IMPACT both PDPM implementation and SNF QRP refinements at the SNF Quality Reporting Program Training page at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Skilled-Nursing-Facility-Quality-Reporting-Program/SNF-Quality-Reporting-Program-Training.html. Important recently released resources providers should look at on this page are:
  • SNF QRP Provider In-Person Training Event, Aug. 13 and 14, 2019 (also available via webcast)
  • May 7 and 8 SNF QRP Provider Training Event (video recordings and slide downloads)
  • Updated Section GG Web-based Training Course (self-paced approximately 45 minutes)
  • Video Tutorials Available to Assist with Coding Specific Section GG Items (4-12 minutes each)
Providers that do not rely on dusty obsolete versions of the MDS-RAI manual and are diligent in keeping MDS coders and clinical staff up to date with these important changes will be better prepared for finding the right road to success under both the PDPM and SNF QRP programs.

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