Several changes to the Minimum Data Set (MDS) assessment went into effect on October 1, 2023. The Resident Assessment Instrument (RAI) manual that directs how MDS assessments are to be completed also was updated. The updated RAI manual includes more coding tips for providers to enhance the accuracy of MDS assessments completed for patients residing in a senior living setting, primarily skilled nursing facilities (SNFs).
One of the most significant changes to the MDS was the removal of Section G, which calculated an activity of daily living (ADL) score used by many state Medicaid payment programs to calculate a resource utilization group (RUG) category. With Section G’s removal, states had a few options of how to proceed with their Medicaid payment models. They could opt to have their providers complete an Other State Assessment (OSA) in addition to the Omnibus Budget Reconciliation Act (OBRA) assessments in order to continue to calculate a RUG category. States could opt not to use the OSA and instead transition to some form of the Patient-Driven Payment Model (PDPM) in the near future.
What does this mean for SNF providers attempting to proactively manage the MDS accuracy and completion process? Ideally, each MDS completed for all residents would be 100% accurate; however, errors do occur. Having processes and systems in place to capture appropriate documentation during the look-back period assists MDS personnel in completing accurate MDS assessments.
With states actively transitioning to some version of PDPM for their Medicaid payment models, there are numerous strategies allowing for proactive management of the MDS process. Assessment reference date (ARD) management is one process that requires an interdisciplinary effort. Through daily standup meetings and consistent communication to discuss changes in patients’ conditions and needed interventions, SNF management teams will be better positioned to effectively manage the MDS assessment process and ARD management.
It also is important to have individuals cross-trained to complete the MDS assessment process. With MDS assessments driving reimbursement for both Medicare and Medicaid, ineffective processes are most likely resulting in missed revenue opportunities. Proactive management of PDPM also requires the collection information related to functional abilities for each resident. The look-back period for functional abilities is always three days—the ARD of the MDS and two days prior. The best practice is that the information is collected from both nursing and therapy staffs to allow the MDS personnel to determine each patient’s usual performance appropriately in Section GG. For those states transitioning to PDPM that are not using the OSA, it would be important that facility personnel understand that therapy days and minutes no longer drive payment and the OBRA assessments now do not allow for coding of this information in Section O.
Providers also need to have processes in place to complete all patient interview sections on or before the ARD of MDS assessments. Most of the resident interview portions of the MDS have a seven-day look-back period, and processes that communicate efficiently with the interdisciplinary team members will be critical to success. These interviews cannot be completed after the ARD.
Also effective on October 1, 2023 was the addition of seven social determinants of health (SDOH) standardized patient assessment data elements (SPADEs). These include ethnicity, race, language, transportation, health literacy, and social isolation. Having a process to collect this information from the resident—possibly during the admission process—would assist the MDS personnel with accurate MDS assessment completion.
For questions related to the updated MDS assessment, recommended process implementation, and state transition to PDPM, please reach out to a professional at FORVIS.