​Accurate data collection and reporting are more important than ever in skilled nursing facilities. Among the challenges is coding section GG of the Minimum Data Set (MDS) that captures usual performance in self-care and mobility tasks. This data also drives care planning, quality reporting, Medicare reimbursement, and, in some states, Medicaid reimbursement, so it has a widespread impact. Thus, addressing and resolving the root cause of any inaccuracies and inconsistencies in a timely way must be a top priority.

Common issues are incomplete or missing observations, inconsistent input across disciplines, or the lack of an interdisciplinary effort to determine usual performance. The quality assurance and performance improvement (QAPI) process is an effective method for facility teams to identify and address the root causes of these issues.

QAPI is designed to be a proactive, data-driven framework that goes beyond compliance to focus on measurable and sustainable improvements. This article shows how to include section GG in the QAPI process. It will help ensure improved accuracy of documentation and coding and also establish a lasting system of accountability and collaboration.

The Role of Section GG in QAPI

Section GG lends itself well to QAPI monitoring because it provides clear, measurable indicators of compliance. Facilities can begin by routinely auditing a sample of assessments each quarter, at least 5 percent of all completed MDS submissions. During these reviews, staff can examine whether each self-care and mobility item was observed, whether the entire 3-day observation window was covered, and whether the input from nurse aides, therapists, nurses, residents, or families was incorporated. The audit should also confirm that discrepancies between disciplines were addressed and resolved before the assessment was finalized.

The approach just described allows the facility to assign a percentage of compliance for each item, creating a set of key performance indicators (KPIs) to track over time. For example, instead of relying on anecdotal impressions (e.g., “our nurses’ aides aren’t documenting enough”), the facility can use concrete numbers that reveal whether compliance is trending up or down.

Understanding the Source of the Issue

Once data is collected, the QAPI committee must ask why errors or inconsistencies are occurring. In some cases, the root of the problem may be related to the process. Staff may not complete all episode documentation on each specific self-care or mobility task or they may not recognize that documentation is required throughout the 3-day window. In other situations, the issue relates to training. Staff may not understand the difference between specific tasks or the performance levels used for section GG. Sometimes the problem is inherent in the systems. For example, electronic health records (EHRs) may not provide sufficient prompts or fields for capturing required information, leaving staff to remember the details on their own. Finally, the culture of the facility may be a factor. Completing documentation and focusing on accuracy may be viewed as a siloed MDS issue, rather than a responsibility of the entire collaborative interdisciplinary team.

Root cause analysis (RCA) should be used to identify the primary cause of the issues identified. Whether through the Five Whys method or a fishbone diagram, facilities can begin to uncover the deeper reasons behind persistent noncompliance. Without identifying the root cause, any efforts to improve section GG documentation risk addressing symptoms rather than causes.

By applying RCA consistently, facilities can move beyond quick fixes and create sustainable improvements. For example, if training gaps are identified as the primary cause, the focus should be on the process or system used for training to ensure staff clearly understand performance levels and documentation expectations. If workflow barriers or EHR limitations are uncovered, processes can be redesigned or system prompts added to guide staff during the observation window. When the root cause is cultural, believing that section GG is solely the responsibility of the nurse assessment coordinators (NACs), leadership can emphasize the shared accountability of the interdisciplinary team, reinforcing that precise documentation reflects the resident’s true abilities. In each case, addressing the root cause leads to more accurate coding, stronger compliance, and ultimately better resident outcomes.

Moving into Action

When section GG issues are isolated or minor, the QAPI team may be able to address them through targeted feedback, training, or process adjustment. But if problems are systemic or persistent, it may require a formal Performance Improvement Project (PIP). A PIP provides structure, scope, and accountability, ensuring that the facility moves beyond merely identifying issues to actively solving them.

For example, if a facility discovers that dashes are used too frequently in GG0130 or GG0170 items, the QAPI team might charter a PIP with the goal of reducing dash use to less than 2 percent of MDS assessments within six months. The project might involve staff training on appropriate coding, daily check-ins during the 3-day assessment window to ensure observations are documented, and routine interdisciplinary reviews before MDS coding. Each step would be monitored through continued audits, with progress shared at QAPI meetings.

To be effective, the PIP must include measurable goals and a clear plan for monitoring progress. Assigning responsibility is also essential. The NAC, therapy staff, nurse aides, and charge nurses all may have distinct roles to play in the plan that the project should make clear.

Sustaining Long Term Improvement

Section GG documentation and coding issues are not a one-time effort. Without reinforcement, even well-executed improvement plans can lose momentum. To ensure long-term success, facilities need to include these practices in their daily routines. It could start with staff orientations, to create a positive culture and clear expectations for the importance of section GG documentation. Ongoing monitoring and education should be scheduled and not just hastily organized when problems arise.

Recognition is another powerful tool to improve a culture focused on accuracy for section GG. When staff meet or exceed compliance goals, celebrating those achievements helps reinforce positive behaviors and encourages a sense of ownership.

Most importantly, QAPI meetings should continue to review section GG compliance until results are consistently strong. Even then, it is wise to revisit section GG periodically to confirm that gains are maintained and to identify new opportunities for refinement. Facilities should also be prepared to adjust their benchmarks upward over time, fostering a culture of continuous improvement.

Conclusion

Section GG documentation and coding are foundational to quality care and accurate reporting in nursing facilities. Yet they are also areas where many facilities stumble, whether through incomplete observations, missing documentation, or lack of interdisciplinary collaboration. By integrating section GG into the QAPI framework, facilities will gain tools to measure performance, identify root causes, implement targeted interventions, and sustain long-term improvement.

Jessie McGill, RN, BSN, RAC-MT, RAC-MTA, is senior curriculum development specialist at the American Association of Post-Acute Care Nursing (AAPACN).

The American Association of Post-Acute Care Nursing (AAPACN) represents more than 17,000 long-term and post-acute nurses and professionals working in more than 5,750 facilities through its subsidiary associations, the American Association of Nurse Assessment Coordination (AANAC) and the American Association of Directors of Nursing Services (AADNS). Learn more at AAPACN.org.