Updates

CMS Revised F641, Accuracy of Assessment, Among Other Tags 

The Centers for Medicare & Medicaid Services (CMS) recently confirmed the revisions to the State Operations Manual (SOM), Appendix PP, which went into effect April 28, 2025. The revisions are redlined here. While many revisions were made, nurse assessment coordinators should especially note changes in F641, Accuracy of Assessment. The following is an excerpt from this updated section: 

INVESTIGATIVE PROCEDURES Use the Resident Assessment Critical Element Pathway a) when MDS concerns are noted but you are not using a care area pathway (i.e., the care area did not require further investigation), or b) for concerns about the facility’s MDS data completion or submission activities, along with the above guidance, when determining if the facility meets the requirements for, or investigating concerns related to resident assessment.

Surveyors are expected to focus on MDS coding accuracy but are not expected to investigate possible falsification of the resident assessment instrument.

Suppose the surveyor identifies a pattern (i.e., three or more residents) of inaccurate MDS coding by staff who completed, signed, and certified to the accuracy of the portion of the assessment they completed, and there are indications or concerns that the individual who completed the section(s) in question knew the coding was inaccurate. In that case, a referral should be made to the Office of Inspector General for investigation of falsification per §483.20(j). See the Submit a Hotline Complaint section, under the Fraud tab, on the Department of Health & Human Services Office of the Inspector General’s webpage.