Ahhh, the end of summer has come! And as sure as Starbucks will start selling their line of pumpkin spice lattes you can also be assured that CMS will release an update to the RAI MDS 3.0 User’s manual. CMS did not disappoint! A manual update was recently released with not only some of the usual updates and revisions, but also some surprises and addition of new MDS items.
Starting at the beginning of the MDS, let’s walk through some of the more impactful changes. Ready? Go!
CMS corrected the two examples found on pages A-35 and A-36 to indicate A0310H (Is this a SNF Part A PPS Discharge Assessment?) would be coded as “1”, Yes instead of “0”, No.
ADL coding clarifications!
- If a mechanical lift is used to transfer a resident between surfaces and the resident holds onto a bar, strap or other device, this should not be considered as resident participation when determining ADL coding.
- Use of a stand-up lift should be coded as extensive assistance as the resident does participate.
- How resident turns from side to side, in the bed, during incontinence care should be coded under Bed Mobility, not Toileting.
- A new ADL algorithm was created to better explain the rule of 3. CMS also clarified how episodes of independence should be reviewed when following the steps in the rule of 3.
G0600 Wheelchair Clarification
- Do not include geri-chairs, reclining chairs with wheels, positioning chairs, scooters and other types of specialty chairs (i.e., Broda) when coding this item.
CMS has stated this verbally for years and now finally has added it to the manual!
Section GG contains numerous clarifications to assist providers in better understanding Section GG coding requirements. Here we demonstrate a few of those clarifications:
- Assessment Performance will need to be completed on any assessment that is coded as an 01 in A0310B (5-day PPS assessment).
- The Discharge Performance with be required to be completed when a resident’s Medicare Part A stay ends. This could occur if a resident remains in the facility or if they are physically discharged. The Discharge Performance would not need to be completed under the following 2 circumstances:
- Resident has an unplanned discharge to an acute care hospital; or
- The SNF PPS Part A stay was < 3 days.
- CMS also added some clarifications and examples to assist providers in accurately coding the wheelchair items in Section GG.
This one is HUGE! CMS is revising the requirements to code a UTI!
- New coding requirements: Code only lf BOTH of the following criteria are met in the last 30 days:
- It was determined that the resident had a UTI using evidence-based criteria such as McGeer, NHSN, or Loeb in the last 30 days; AND
- A physician or NPP documented a UTI diagnosis in the last 30 days.
- This may be a welcome change as it appears to fall in line with many policies facilities currently follow for determining a UTI in their infection control programs.
CMS adds several new items to this Section:
- CMS has added Opioids as a classification of medications in Section N. Follow the same coding rules as the other medications classifications listed in N0410.
- CMS has also clarified that the use of Target Specific Oral Anticoagulants (e.g., Pradaxa, Xarelto, Eliquis) should be coded in N0410E (Anticoagulants).
- An Antipsychotic Medication Review (N0450) has been added. This section is composed of 5 different questions.
- Did the resident receive antipsychotic medications?
- Was a gradual dose reduction (GDR) attempted?
- Date of the last attempted GDR, if applicable?
- Is there physician documentation indicating a GDR is clinically contraindicated?
- Date of physician documentation, if applicable.
- Added clarifying information related to coding respiratory therapy services on the MDS.
- CMS will no longer require the completion of O0600 (Physician Examination) and O0700 (Physician Orders). Unless required by your state.
PLEASE CHECK WITH YOUR STATE ON REQUIREMENTS FOR THESE TWO ITEMS!
- If the state does not require the completion of O0600 and O0700, these items may be dashed.
- For O0700, CMS now includes orders written by qualified dietitians, clinically qualified nutrition professionals or qualified therapists, working in collaboration with the physician as allowable by state law.
CMS also added new items in this section related to use of alarms
- P0200 Alarms has been added to Section P of the MDS.
- This item assesses the use of various types of bed alarms used in nursing facilities.
Side Note: CMS has not proposed any change to the Restraint quality measure. At the current time these new items will not be utilized in this particular QM calculation.
In addition to the above, some additional revisions/clarifications were also issued for Sections H, J, L, M, and Q.
To review all the CMS RAI Manual revisions and updated manual pages, click here.
Ensure all staff involved in the coding of the MDS is now aware of these MDS coding revisions, clarifications and additions that go into effect on 10/1/2017.