CMS stated very clearly from the infancy stages of development of the MDS 3.0 that this tool is designed to capture the patient's voice as well as interdisciplinary findings. There are a number of sections on the MDS 3.0 tool that can be influenced and impacted by the consultation and provision of skilled therapy services. Education for the Medicare team should be on-going to review the coding instructions for the MDS. Misinformation regarding the coding elements on the MDS can lead to inaccurate reimbursement under both Medicare and Medicaid programs as well as risk for non-compliance under Medical Review. Inaccurate coding of the MDS can also have serious survey implications.
Therapy professionals should be aware of how and why their expertise is valuable for completing the following sections: C, D, E, H, J, K, M, O, P, Q. Reading the RAI manual is a great place to start. The manual outlines specific care components as well as patient manifestations which when observed must be coded on the MDS. As insightful as the RAI manual is, there are areas which remain grey regarding the coding instructions. When a facility is unsure of how to proceed with a particular section, it is recommended that they contact their Medicare Contractor to provide clarity. Consistency in coding will lend to compliance and capture of all reimbursement related services the facility is entitled to. As well, it will behoove the facility to establish a protocol through a policy and procedure outlining facility specific guidelines for any sections which have the potential to be inconsistently coded. Example sections where this could occur include: Section G, Section O and Section M.
The Rehab Manager, at a minimum, must have a clear understanding of the types of MDS assessments and the criteria for utilization of these assessments to allow for a compliant landscape and revenue management. The Start of Therapy and End of Therapy OMRA are two examples of assessments that must be managed by the team for the most advantageous result.