Contact Me

Do You Have a PASRR Questions?

Test Your Knowledge Answers: 

1) Wound infections cannot be coded as isolation. Per Chapter 3, Section O, page O-8 of the updated RAI User's Manual:

Alone in a separate room because of active infection (e.g., symptomatic and/or have a positive test and are in the contagious stage) with highly transmissible or epidemiologically significant pathogens that have been acquired by physical contact or airborne or droplet transmission. Do not code this item if the resident only has a history of infectious disease (e.g., s/p MRSA or s/p C-Diff - no active symptoms). Do not code this item if the precautions are standard precautions, because these types of precautions apply to everyone. Standard precautions include hand hygiene compliance and glove use and additionally may include masks, eye protection, and gowns. Examples of when the isolation criterion would not apply include urinary tract infections, encapsulated pneumonia, and wound infections.

2) No, the completion and submission requirements for the MDSs have not been impacted by the MDS version change on 10-01-23. There is no "transition" to complete going from September to October. There is no requirement that September assessments must be completed by October 1. 

3) From the 09-20-23 QSO:

Updating CMS forms 671 and 672:

The changes to the MDS also necessitate changes to forms that are completed on surveys. Specifically, fields on the CMS-672 form can no longer be completed due to the removal of Section G from the MDS. Also, CMS and surveyors no longer use these MDS-based fields on the CMS-672 form as part of the survey process. Therefore, effective September 29, 2023, facilities are no longer required to complete these fields (F79 – F145) and surveyors are no longer required to enter this information (fields F79 – 93) in the survey system. The census information (fields F75-F78), the ombudsman information (fields F146 and F147), and the medication error rate (field F148) should still be completed. On October 22, the census, medication error rate, and ombudsman information fields will be relocated to the form CMS-671, and the CMS-672 form will be removed. This change will help streamline the survey process for surveyors and facilities. We are aware that researchers and other stakeholders may use CMS-672 data, so we will be exploring other ways to make MDS-based data publicly available to all stakeholders through a separate mechanism. 

4) The GG assessments must be completed within the 3-day look-back window for each MDS. 

5) a. Your software should NOT pull in GG answers from CNA documentation. Section GG is to be coded based on ASSESSMENTs completed by Qualified Clinicians. The Rule of Three is not being used for Section GG and CNAs are not Qualified Clinicians who can do assessments. Qualified Clinicians must do the GG assessments within the 3-day assessment window for each MDS with ARDs on or after 10/1/2023.  

b. No, therapists should not evaluate all residents for each MDS--this would not be an appropriate use of Medicare money for evaluations and would not be medically reasonable and necessary. If therapy is working with a particular resident during an assessment window by all means obtain their input for the GG assessments.

c. Sections B and C are still on the MDSs for 10/1/2023. Only Section G went away.

6) It had no impact on billing. Nothing changes but you are out of compliance with timely completion. You only have until day 14 with Admissions to complete the entire MDS and CAA. The 5-day is not late.  We are allowed 14 days from the ARD for PPS MDSs. The admission MDS is late. This is a survey issue, not a payment issue unless the admission was required for Case Mix.

7) Race and ethnicity items are interview items. These interviews need to be conducted for every MDS within the 7-day look-back. The responses from one MDS cannot be carried forward to the next.  New interviews must be conducted within the 7-day look back every MDS. 

8) Here is what the RAI User's Manual says in Chapter 2, pages 2-33 and 2-34:

If a resident goes to the hospital (discharge return anticipated and returns within 30 days) and returns during the assessment period and most of the assessment was completed prior to the hospitalization, then the nursing home may wish to continue with the original assessment, provided the resident does not meet the criteria for an SCSA.

For example: 

• Resident A has a Quarterly assessment with an ARD of March 20th. The facility staff finished most of the assessment. The resident is discharged (return anticipated) to the hospital on March 23rd and returns on March 25th. A review of the information from the discharging hospital reveals that there is not any significant change in status for the resident. Therefore, the facility staff continue with the assessment that was not fully completed before discharge and may complete the assessment by April 3rd (which is day 14 after the ARD).
  
  Resident B also has a Quarterly assessment with an ARD of March 20th. They go to the hospital on March 20th and return on March 30th. While there is no significant change the facility decides to start a new assessment and sets the ARD for April 2nd and completes the assessment.
  
  If a resident is discharged during this assessment process, then whatever portions of the RAI that have been completed must be maintained in the resident's discharge record.6 In closing the record, the nursing home should note why the RAI was not completed.
  
  If a resident dies during this assessment process, completion of the assessment is not required. Whatever portions of the RAI that have been completed must be maintained in the resident's medical record. When closing the record, the nursing home should document why the RAI was not completed.
  
  If a significant change in status is identified in the process of completing any assessment except Admission and SCSAs, code and complete the assessment as a comprehensive SCSA instead. 

Since the resident was identified as having an SCSA, there are two options; 1) finish the assessment that was started before the discharge, or 2) complete it within 14 days of the readmission. Most likely a late message will be received since the quarterly was due with ARD on 9/23/2023. If the quarterly with an ARD of 9/23/2023 was not opened, it cannot be opened now since the window closed for setting the ARD of that Quarterly on day 92 (9/23).  If you had that Quarterly open with the ARD on or before 9/23, it could be completed. But if not, set the ARD for the SCSA and complete that MDS only.

9) The SDOH items for Race and Ethnicity are on the entry tracking forms and every OBRA and PPS MDS including OBRA discharges. 

10) The forms can be printed from the RAI User's Manual 

11) Per the instructions only complete O0400 when A0310B=01(5-day). If a stand-alone admission is being completed, then no therapies would not be encoded into the MDS. The only time section therapies are entered is on a 5-day and or an Optional State Assessment (OSA).

12) Column 1 is based on drug class. Column 2 is based on documentation of the prescriber's rationale, regardless of drug class. Therefore, column 2 would be checked.

13) Yes, therapy information is no longer collected on OBRA MDSs. Therapy minutes are only documented on the 5-day MDS and End of Medicare Stay assessment. 

14) Although an SCSA was completed on 10/3/2023, an SCSA must be completed on or after the date hospice began. The MDS could be left as a Quarterly assessment and the SCSA could be completed within 14 days of when hospice started. However, if the SCSA dated 10/3/2023 has been transmitted, another SCSA needs to be completed so hospice and nursing home care plans can be correctly integrated. 

15) An Admission MDS is completed only once for each resident unless they have been discharged with a return NOT anticipated or discharged with a return anticipated but did not return within 30 days. When there is a discharge with a return anticipated (hospitalization is a good example) and the resident returns within 30 days, no new Admission MDS can be completed if one has been completed since their original admission (A1900). The IDT may want to assess for a SCSA. If it is determined there has not been an SCSA, the OBRA schedule will continue where it left off when the resident was discharged.  On the reentry tracking form, A1700 would be coded as 2. 

16) The updates from CMS and the RAI User's Manual say that if a full body mechanical lift is used the activity of lying to sitting and sit to lying would be coded using the appropriate activity did not occur reason. 

17) Only one discharge goal is required to be set, but there can be more than just one. Each Section GG item that is set with a discharge goal should have a care plan. When a goal has been set on the MDS, there should be a care plan for that item with the chosen goal to be met by the Medicare end date. 

18) A 5-day is required to get paid at a PDPM rate for the first few days. If the 5-day had been created and the ARD set onto the item set prior to the DIF, then adjust the ARD of the 5-day to the date of death and complete. If the 5-day had not yet been created prior to the resident's death, it cannot be completed now, and the days would be billed at the default rate. 

19)  At least one goal for Section GG is still required to be set and care planned. The remaining discharge goal items can be dashed. The change on October 1st is that this will no longer be a SNF QRP Measure, but it is still a requirement.

See the RAI User's Manual, Chapter 3, Section GG, page GG-34:

GG0130: Self-Care (cont.)

Discharge Goals: Coding Tips

Discharge goals are coded with each Admission assessment when A0310B = 01, indicating the start of a PPS stay. Discharge goals are not required with stand-alone OBRA assessments.

For the SNF Quality Reporting Program (QRP), a minimum of one self-care or mobility discharge goal must be coded. However, facilities may choose to complete more than one self-care or mobility discharge goal. Code the resident's discharge goal(s) using the six-point scale. Identifying multiple goals helps to ensure that the assessment accurately reflects resident status and facilitates person-centered individualized care planning. Use of the "activity was not attempted" codes (07, 09, 10, and 88) is permissible to code discharge goal(s). Use of a dash is permissible for any remaining self-care or mobility goals that were not coded. Of note, at least one Discharge Goal must be indicated for either Self-Care or Mobility. Using the dash in this allowed instance after the coding of at least one goal does not affect the Annual Payment Update (APU) determination.

Licensed, qualified clinicians can establish a resident's Discharge Goal(s) at the time of admission based on the resident's prior medical condition, admission assessment self-care and mobility status, discussions with the resident and family, professional judgment, practice standards, expected treatments, the resident's motivation to improve, anticipated length of stay, and the resident's discharge plan. Goals should be established as part of the resident's care plan.•

If the admission performance of an activity was coded 88, Not attempted due to medical condition or safety concern during the admission assessment, a Discharge Goal may be entered using the 6-point scale if the resident is expected to be able to perform the activity by discharge. 

20) Item N0415 technically does not ask for a diagnosis. Instead, it is asking for an appropriate indication. In the box on page N-6 of the manual, Indication is defined as "The identified, documented clinical rationale for administering a medication that is based on a physician's assessment..." So, for example - if you're given Aspirin (an antiplatelet), for "DVT prophylaxis", it still counts as "indication noted" even though it's not really a diagnosis. 

Indications for use are not always diagnoses. Often they are manifestions instead. That is why the physician should document the indication for each medication's use.