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Seasons are changing, and so are the MDS 3.0 rules!

The start of FY2017 is quickly approaching with the accompanying MDS 3.0 changes effective 10/1. Unfortunately, much confusion related to coding the new Section GG remains. The accuracy of data collection for Section GG is important as failure may potentially lead to future provider payment penalties. This issue of the Proactive newsletter shares answers to frequently asked questions.

Q: If someone admits on 09/28 with an ARD in October, do we need to do Section GG in September?

A: MDS version 1.14 item sets with Section GG must be used for any assessment with an ARD of 10/1/2016 or later that requires section GG. This is confusing because the collection of GG data to calculate SNF QRP Quality Measures (QMs) will actually start with traditional Medicare Part A admissions on or after 10/1/16. Section GG for admissions prior to October 1, 2016 will not count towards the SNF QRP Quality Measures.

Q: The final version of the RAI Manual states that the admission assessment for section GG should occur prior to the start of therapeutic intervention. Does this mean the look-back will only be on PPS days prior to the therapy evaluation?

A: The final version does include reference to assessment prior to the start of therapeutic intervention on page GG-4. The instructions do not specifically state that we have to assess for the entire 3 days, it only states that the assessment must take place within the first three days and prior to therapeutic intervention. So, if the therapy plans of care are established prior to PPS day 3, the usual performance can be determined based on information from nursing assessments and therapy evaluation(s) that are recorded prior to the start of therapy treatment.

Q: Our facility has decided to have therapy complete the mobility portion of Section GG since they have the most knowledge in this area. Is this okay?

A: Facilities have responsibility to ensure the most appropriate and trained individual in your facility completes each section of the MDS. The gathering of the information that makes up Section GG should be completed collaboratively with the interdisciplinary team’s feedback, such as nursing and therapy, etc.

Q: Often we have residents who plan to go home on a specified day and then decide to leave earlier. We also frequently have residents who decide to discharge home “tomorrow.” Is this considered a planned or unplanned discharge?

A: Any time a resident suddenly decides to leave, it is an unplanned discharge. When a resident decides to leave the next day or even the day after that , it does limit the facility’s ability to arrange for any needed resources and also to complete the resident interviews for the Discharge assessment. However, consultation with your state RAI coordinator for state specific guidance is also advised , as CMS cautions overuse of unplanned discharges.

Q: I am confused in situations where Medicare coverage ends on a Monday and the resident discharges on a Tuesday. How do I code the MDS?

A: This information is found on page A-33 in chapter 3 of the RAI User’s Manual; there is also a Medicare Stay End Date Algorithm on page A-37. “The end of Medicare date is coded as follows, whichever occurs first: Date SNF benefit exhausts (i.e., the 100th day of the benefit); or Date of last day covered as recorded on the effective date from the Notice of Medicare Non-Coverage (NOMNC); or The last paid day of Medicare A when payer source changes to another payer (regardless if the resident was moved to another bed or not); or Date the resident was discharged from the facility (see Item A2000, Discharge Date).”

Q: Can I complete a Medicare PPS Discharge Assessment combined with an unscheduled PPS assessment?

A: The Part A PPS Discharge assessment can’t be combined with any unscheduled PPS assessment, because there is no item set that can accommodate that. Page 2-55 of manual: “If the date listed in A2400C is on or after Day 7 of the COT observation period, then a COT OMRA would be required if all other conditions are met. If the date listed in A2400C is on Day 7 of the COT observation period, then the SNF must complete both the COT OMRA and the Part A PPS Discharge Assessment. These assessments must be completed separately.”

Q: Do we have to document each day; days 1, 2 and 3? Or, can we document once that summarizes on the most “usual” functional status on day 1 to 3?

A: Keep in mind that you need to have documentation to support each response on your MDS; an auditor should be able to arrive at the same coding choice based on the documentation recorded. Best practice is documentation from each shift. At a minimum the documentation should include a daily summary.

Q: We are having trouble in distinguishing the difference between code 88 (not attempted due to medical condition or safety concern) and code 09 (resident did not perform this activity prior to current illness). Could you please clarify?

A: Think in terms of new conditions versus prior level of function. If it’s been established that the resident did not perform the activity prior to this illness, injury, or exacerbation, then you would code 09. If the activity is not performed due to a new medical condition with safety concerns you would code 88.

Q: What if the resident has attempted a mobility task such as walking 50 feet, but was not successful? How would this be coded?

A: Even though the task is technically attempted, you would code 88 if the failure to complete the task was related to the medical condition. Reference page GG-32 of the RAI Manual for specific example.

Q: Does Section GG have to be completed and signed on or before PPS day 3?

A: The published instructions say that the GG assessments must be “completed” within the 3-day observation periods. This implies the data itself needs to be from documentation within the first three PPS days.

Proactive Medical Review offers specialized clinical risk management consulting services to support the proactive management, prevention, and mitigation of risk through Quality Assurance and Performance Improvement (QAPI) efforts designed to achieve and sustain quality outcomes.

For more information on how Proactive Medical Review can assist you to prepare for Section GG and SNF Quality Reporting, along with the upcoming changes to the RAI manual, please contact us at 812-471-7777.

Amie Martin, OTR/L, CHC, RAC-CT
Proactive Medical Review & Consulting, LLC
amartin@proactivemedicalreview.com