​The response was immediate when the Centers for Medicare & Medicaid Services (CMS) announced significant changes to the minimum data set (MDS) assessment starting October 1, 2023. Confusion, speculation, and apprehension followed. Questions like, “When is the RAI manual coming out?” and “What’s happening with Section G?” were posted to many MDS groups and chats.

It’s smart to be apprehensive: this will be the biggest change to the MDS assessment in over 10 years. As an MDS coordinator and leader of MDS nurse teams for decades, I believe the MDS assessment is one of the most important yet least understood tools a facility uses. The MDS process, when completed accurately, drives reimbursement, compliance, and resident care—every key component of operating a successful facility.

But if the MDS assessment is so important, why are facilities unprepared?

Why Facilities Aren’t Prepared for the MDS 3.0

1. MDS coordinator vacancies and “borrowing” the MDS coordinator for other tasks. Preparing for the new MDS assessment goes beyond understanding the latest changes. Facilities are struggling to submit accurate assessments today because there’s a nationwide shortage of qualified MDS coordinators. MDS nurses who have stayed in the industry are stretched thin. We’ve all seen or heard of an MDS coordinator being asked to deliver trays, assist with activities of daily living, or pass medication when direct care staff is lacking. “Borrowing” an MDS coordinator compromises your reimbursement. Worse, it creates a culture where MDS coordinators feel underappreciated and unable to complete their jobs effectively.

I manage a team of remote MDS coordinators, and one of our coordinators recently supported a facility that had almost 100 overdue assessments. Leadership was overjoyed when she got the facility back on track, but it turns out the problem went deeper. She began reviewing old assessments and discovered missing sections, inaccurate coding, and sparse documentation. The facility’s original MDS coordinator and facility leadership were doing the best they could, but the MDS coordinator was spending half her time filling other staffing gaps. That meant 50 percent less time to do the assessments well.

Plugging general staffing gaps with an MDS coordinator temporarily fixes one problem, but it creates financial and retention issues. There’s no replacement for a skilled and focused MDS coordinator.

2. Underinvestment in MDS coordinator education and networking. It takes long-term training and support to make a great MDS coordinator. Unfortunately, MDS coordinators are sometimes still seen as just a data entry role. That couldn’t be further from the truth! MDS coordinators need to be knowledgeable about residents’ clinical needs, experts in the patient driven payment model, and have their finger on the pulse of the regulatory environment. Oftentimes they’re the only MDS coordinator within a facility, so they need a rich professional network they can turn to with questions or advice on best practices. Between filling in for other staff and juggling competing responsibilities, most MDS coordinators don’t have enough time to attend training, read up on industry changes, or connect with their peers. As a result, MDS coordinators face challenges preparing for the MDS 3.0 as well as mastering the current assessment process.

3. Section GG isn’t coded correctly today and will be a key section in October. A great example of ongoing knowledge gaps is Section GG. One of the major changes in the MDS assessment is the complete replacement of Section G with Section GG. Section GG uses a different type of assessment and is reported over a shorter amount of time than Section G. Today, many MDS coordinators are handling GG unassisted or with very little input from the rest of the clinical team. However, Section GG is intended to capture a more real-life picture of the resident’s functional ability, which requires more attention by the MDS coordinator and a lot more input from the rest of the facility team. 

In my experience, Section GG is incorrectly coded due to a lack of understanding of the section as well as inaccurate or incomplete documentation. That’s why it is important to educate existing and new interdisciplinary team members on accurate coding for GG and supplemental documentation requirements. 

How to Prepare for the New MDS in October

1. Hire a remote MDS coordinator. We need to create environments where MDS coordinators have dedicated time to complete MDS documentation accurately and completely. One possible solution? Remote MDS coordinators.

I had reservations when I first heard about the concept of remote MDS coordinators. However, I quickly realized the advantages of this approach. Originally implemented as a response to COVID-19 concerns, the remote solution has taken off like wildfire in the last three years. Facilities have a bigger pool of MDS coordinator talent to pull from, and remote MDS coordinators are happier when they can fully focus on the MDS without onsite distractions or pressures.

Skilled and focused MDS coordinators lead to thorough MDS assessments, which lead to accurate reimbursement.

2. Hire MDS coordinators who are interested in learning and invest in your coordinator’s continued education. Today I manage a team of remote MDS coordinators serving facilities across the United States. We have daily check-ins, twice weekly group huddles, and a dedicated team chat—all so our coordinators can troubleshoot, strategize, and learn from each other. Our facilities get the insight of not one but a team of coordinators. 

That level of support and teamwork may not be possible for a facility with a single MDS nurse, but support strategies are important. Conferences, training, and networking events are crucial to foster support and camaraderie in a position that requires teamwork but can be quite isolated. Plant those seeds of support now. It will make it easier for your coordinator to prepare for upcoming changes and find help when they hit roadblocks or questions in implementation.

3. Start training on the new MDS (especially Section GG) now and run internal audits. If you haven’t already, start training your entire staff on Section GG. If your current MDS coordinator isn’t strong on GG, don’t be afraid to bring in outside expertise. There will be no hiding technical weaknesses in the months ahead, and it’s always a good idea to brush up on the assessment as a whole. We had our remote MDS coordinators start training CNAs, therapists, and dieticians on Section GG earlier this year, and they train on real-world MDS assessment examples. It’s great to see how confident facilities feel about the upcoming changes, and training makes a difference on the current assessment.

Internal audits are another good way to identify and train on MDS assessment gaps. In our team, during group huddles we’ll walk through an assessment together and discuss how to code trickier case scenarios or what steps to take to collect proper documentation. We’ve developed a true team of MDS excellence through this approach, but any facility can implement these suggestions.

Decoding the new MDS isn’t easy, but with the right coordinator and the right system to support them, you can shorten the learning curve. The American Association of Post-Acute Care Nursing is one organization with excellent training resources available, and there’s a wealth of information from industry leaders who have been through similar changes before. Don’t be afraid to think creatively about remote MDS coordinators, and don’t wait until October. Take charge of your MDS 3.0 prep now.

Rita Frieder, RN, RAC-CTA, is the MDS department manager at Polaris Group. She has more than 40 years of experience in long-term care, starting as a CNA, and has led individual facilities and corporate chains as an MDSC, ADON, DON, and nurse consultant.