Minimum Data Set Changes Coming in October – Are You Ready?
Today’s blog is brought to you by CLA’s Deb Emerson and Jillian Martin.
Background
On October 1, 2019, the skilled nursing industry experienced the change in Medicare Part A payment methodology from the Resource Utilization Groups (RUGs) based payment to a patient driven payment model, or PDPM. The PDPM included implementation of Section GG of the Minimum Data Set (MDS).
While there were not a significant number of MDS question changes, the preparation for those changes was time consuming and sometimes confusing. Many of the changes directly impacted the calculation of the PDPM payment rate. At that time, the Center for Medicare and Medicaid Services (CMS) indicated further changes to the MDS would be coming.
New Changes
In April of 2023, CMS issued those additional draft MDS changes to be implemented on October 1, 2023. Beginning October 1, 2023, CMS will no longer support the Medicare RUGs system and is ending the support for RUG-III and RUG-IV on federally required assessments. In addition, CMS issued a letter to State Medicaid directors in September 2022 with guidance on nursing facility statement plan payment and upper payment limit approaches in Medicaid that rely on the Medicare PDPM model.
So, why did CMS make these changes to the MDS?
Many of the questions in the MDS have changed to create a standardized assessment across all post-acute care settings, including Skilled Nursing Facilities, Home Health Agencies, Long Term Care Acute Care Hospitals, and Inpatient Rehab Facilities. The IMPACT Act of 2014 laid out the groundwork for gathering Standardized Patient Assessment Data Elements to allow CMS to evaluate what post-acute care settings are providing better care at a lower cost. In addition, CMS made some changes as part of keeping residents at the center of their own healthcare decision-making and to determine what, if any, barriers exist. Therefore, questions were added to the MDS or amended to monitor for Social Determinants of Health.
Section G and Section GG Changes
The biggest change to the MDS is the removal of Section G, functional status. While some of the Section G questions have been transitioned to section GG, most of the questions and coding guidelines will be eliminated. Some states may opt to keep section G as part of their Optional State Assessment (OSA), but it is not required federally.
Since we began using section GG, functional abilities and goals, CMS has indicated that it should be an interdisciplinary assessment. Interdisciplinary for this section means that nursing, therapy, and Certified Nursing Assistants (CNAs) should document the resident’s status over a specified three-day period and the nursing assessment coordinator (NAC) should determine the usual performance that will be coded on the specified MDS.
Working to educate your nurses and CNAs now on these changes will allow for a smoother transition come October. Facilities should consider a stop date for your current Activities of Daily Living (ADL) flow sheet that is typically representative of section G questions and then a start date for a new flow sheet, if that is how they choose to capture the documentation.
Sections K, N Changes
There are other major changes in the MDS that will have large Interdisciplinary Team (IDT) implications. Section K includes changes to the timeframes for evaluating questions. Facilities will have to answer the Section K questions based upon four timeframes, rather than the current two, “while not a resident” and “while a resident.”
Section N also has significant changes related to expanded medication categories and two questions on whether the patient is taking the medication, or the medication is indicated.
Steps To Take Now
What should you be doing to prepare for the MDS changes on October 1, 2023?
- It is important to make sure the IDT is aware of the changes. The IDT should obtain the updated MDS 3.0 RAI User’s manual, keep up with information as it is released by CMS related to changes, and consider MDS certification training for MDS coordinators.
- Review how each member of the IDT might be impacted and how the organization will update processes for those IDT members.
- Determine how care plans are going to be updated to incorporate the functional abilities found in Section GG, rather than the functional status wording of section G. This will be a rolling process and not every resident will need an updated care plan in October. However, as quarterly, annual, or significant change assessments are completed, facilities should sunset traditional ADL care plans and write a new ADL care plan with functional assessment and goal wording to more in line with MDS/RAI expectations.
- Determine any other process that may need to change in the organization related to the admission or discharge process. For example, providing a reconciled medication list at discharge.
How CLA Can Help
CLA can help in training IDT members in updating processes, providing education regarding the changes, and reviewing the processes for compliance with the RAI Manual. Whatever your SNF needs are, we are here to help.
Jennifer Boese is the Director of Health Care Policy at CLA. She is a highly successful public policy, legislative, advocacy and political affairs leader, including working in both the state and federal government as well as the private sector. She brings over 20 years of government relations and public policy knowledge with her to CLA. Well over half of her career has been spent dedicated to health care policy and the health care industry, affording her a deep understanding of the health care market and environment, health care organizations and health care stakeholders. Her role at CLA is to provide thought leadership, policy analysis and strategic insights to health care providers across the continuum related to the industry's ongoing transformation towards value. A key focus of that work is on market innovations and emerging payment models. Her goal is to help CLA clients navigate and thrive in an increasingly dynamic health care environment.
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