Medication Reporting in PASRR

From the PASRR Newsletter 12/20/2023

When submitting a PASRR Level 1 screen, please base your answers on all current medications at the time of the PASRR submission. We recognize that this may include psychotropic medications being used in the hospital that may not continue once the individual is discharged from the hospital. 

You have the opportunity in Level 1 to explain if the treatment plan is to discontinue the use of that medication before hospital discharge. 

Controversy on How Transfers with a Hoyer Lift Clarified

The question noted below (similar to the one noted above) was submitted. It is imperative that the coding be understood and applied the same due to the impact on Function Scores and Quality Measure calculations. 

Question: When a resident transfers via Hoyer lift, they are never sitting on the edge of the bed. Does this mean coding "Did not occur" for all bed/chair transfers for residents with hoyer lifts? We are looking to CMS's clarification specifically as responses received from State RAI Coordinators have varied in the past and we would all like to be interpreting/coding the same. If everyone is on the same page for coding then it facilitates accurate Function scores which impact PDPM and Quality Measures. If the answer to the question posed is the transfer did not occur because it did not start with the resident sitting at the edge of the bed then should "slide board" transfers be removed from the instructions due to use of a slide board can eliminate a resident from sitting on the edge of the bed? Additionally, if not to be coded as "dependent" it is misleading as to the time it takes to care for this type of resident. It would lead you to believe the resident is bed-bound.

Response: 

The intent of GG0170E – Chair/bed-to-chair transfer is to assess the patient's ability to transfer to and from a bed to a chair (or wheelchair).

The activities of GG0170B, Sit to lying, and GG0170C, Lying to sitting on side of bed, are two separate activities that are not assessed as part of GG0170E.

If a mechanical lift is used to assist in transferring a resident for a chair/bed-to-chair transfer and two helpers are needed to assist with the mechanical lift transfer, then code as 01, Dependent, even if the resident assists with any part of the chair/bed-to-chair transfer.

CMS does not provide an exhaustive list of assistive devices that may be used when coding self-care and mobility activities.  Clinical assessments may include any device or equipment that the resident can use to allow them to safely complete the activity as independently as possible.

Only use the "activity not attempted codes" if the activity did not occur; that is, the resident did not perform the activity and a helper did not perform that activity for the resident.

This response is intended to provide guidance related to questions received by this CMS Help Desk.  Information contained in this response may be superseded by guidance or specifications published by CMS at a later date.

To clarify, a follow-up question was submitted: The main issue that is causing controversy is that the instructions state for the Chair/bed-to-chair transfer " the assessment begins with the resident sitting on the side of the bed".  If a Hoyer lift (full body lift) is used the resident does not ever sit on the side of the bed.  Would the resident be coded a "dependent" for this specific question?  The only time you would code using the "Not applicable" codes is if the resident didn't transfer out of the bed during the lookback. You would not use "not applicable" just because the resident didn't sit on the side of the bed to start – correct?

Response:

The intent of GG0170E - Chair/bed-to-chair transfer is to assess the patient's ability to transfer to and from a bed to a chair (or wheelchair).

If the activity was completed during the assessment period (e.g., the patient transferred to and from a bed to a chair), code based on the type and amount of assistance provided for the activity to be completed safely.

Use of an "activity not attempted" code should occur only after determining that the activity is not completed, and the performance code cannot be determined based on patient/caregiver reports, collaboration with other facility staff, or assessment of similar activities.

For reference, please see Example #3 for GG0170E, Chair/bed-to-chair transfer in the MDS RAI 3.0 Manual:

Resident F's medical conditions include morbid obesity, diabetes mellitus, and sepsis, and they recently underwent bilateral above-the-knee amputations. Resident F requires full assistance with transfers from the bed to the wheelchair using a lift device. Two certified nursing assistants are required for safety when using the device to transfer Resident F from the bed to a wheelchair. Resident F is unable to assist in the transfer from their bed to the wheelchair.

Coding: GG0170E would be coded 01, Dependent.

Rationale: The two helpers completed all the effort for the activity of chair/bed-to-chair transfer. If two or more helpers are required to assist the resident in completing an activity, code as 01, Dependent.