Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
We continue our MDS 3.0 Updates Q&A with Part III of our IV-part series. Today’s blog post takes a closer look at Section GG and Drug Regimen Review. With the looming regulatory changes, we encourage you to reach out to your facility’s Harmony HealthCARE Specialist if you have additional questions. As previously stated, the more educated the healthcare professional, the better the care that is rendered the patient.
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Question and Answer with Sally Fecto Sr. VP Field Operations Harmony Healthcare International (HHI)
- Section GG are the discharge goals based on the long-term goals?
Discharge goals may be determined based on the resident’s admission functional status, prior functioning, medical conditions/comorbidities, discussions with the resident and family, and the clinician’s consideration of expected treatments, and resident’s motivation to improve. The goals may align with the Long-Term goals, anticipated to be met by discharge.
- If two ulcers merge to one, what happens to the count of number of ulcers?
If two pressure ulcers merge, code as one pressure ulcer.
- I am new to the MDS. When should section GG be coded once the patient is admitted and once they are discharged?
Yes, Section GG Is completed on the 5-Day MDS and the physical Discharge/ Nursing Home PPS End of Medicare Stay Assessments, or stand-alone NPE. Assess the resident’s self-care performance based on direct observation, as well as the resident’s self-report and reports from qualified clinicians, care staff, or family. Document this level during the three-day assessment period.
CMS anticipates that an interdisciplinary team of qualified clinicians is involved in assessing the resident during the three-day assessment period. Collect and complete the Functional Assessment of the “usual performance” during the first 3 days for the Admission Functional Assessment. This mean completed within the first three days (3 calendar days) of the Medicare Part A stay, starting with the date in A2400B.
Prior to the planned discharge, collect the ‘usual performance” during the last 3 days Discharge Functional Assessment. Keep in mind that an unplanned discharge does not require a Discharge Functional Assessment.
- Is there any advantage or disadvantage entering discharge goals for ALL items of section GG?
Not in my opinion, evaluation and goal setting is important to effective and successful discharge planning. If goals are identifiable, they should be coded and if a goal is unable to be determined, code using the appropriate code.
- For Section GG are we still required to input one (1) self-care goal and one mobility goal? If yes, will you be penalized if you have a resident who does not have any PT or mobility goals (due to their condition)?
For the SNF Quality Reporting Program (QRP), a minimum of one self-care mobility discharge goal must be coded. However, facilities may choose to complete more than one self-care or mobility discharge goal.
If the resident is unable to perform the activity (88) due to medical condition or safety concerns, a discharge goal may still be set.
- Who is responsible for the medication review? If the physician signs off, is that considered a med review?
Not necessarily. It begins with Medication Reconciliation to include OTC, oxygen and TPN. The Team participates in the Drug Regimen Review an ongoing basis, not just upon admission. Team members may include the physician, dietitian, nurse and pharmacist.
The MDS question posed is,
- Did a complete drug regimen review identify potential clinically significant medication issues? See definition of potential clinically significant medication issues. This may include medication omission or non-compliance, to name a few concerns.
- Did the facility contact a physician (or physician-designee) by midnight of the next calendar day and complete prescribed/ recommended actions in response to the identified potential clinically significant medication issues?
- Did the facility contact and complete physician (or physician-designee) prescribed/recommended actions by midnight of the next calendar day each time potential clinically significant medication issues were identified since the admission?
The intent of this drug regimen review items is to document whether a drug regimen review was conducted upon the resident’s admission (start of Skilled Nursing Facility [SNF] Prospective Payment System [PPS] stay) and throughout the resident’s stay (through Part A PPS discharge) and whether any clinically significant medication issues identified were addressed in a timely manner.
- Does a pharmacist need to do the Drug Regimen Review?
The pharmacist is part of the team and performs a drug regimen review when reviewing and dispensing the admission orders, performing on site reviews and with filling new medication orders. Any potential concerns are communicated to the nurse and or physician for review.
- Who is supposed to do the Drug regimen review?
The interdisciplinary team is involved- physician, nurse, pharmacist and dietitian, to name some. This is likely initiated with the review of transfer records/orders and an admission medication reconciliation with collaboration with physician and pharmacist.
- What was the reasoning why the drug regimen review was added to the MDS?
The intent of this review is to identify and address any clinically significant medication issues in a timely fashion. Further, to implement a system to ensure that each resident’s medication usage is evaluated upon admission and on an ongoing basis and that risks and problems are identified and acted upon. With the SNF QRP- Drug Regimen Review Conducted with Follow-Up for Identified Issues – PAC SNF QRP collects data effective October 1st.
The denominator is the number of stays in the selected time window for SNF residents with a SNF PPS Part A Discharge Assessment (A0310H = 1) during the reporting period. Specific denominator definitions for each setting are provided below.
The numerator is the number of stays in the denominator where the medical record contains documentation of a drug regimen review conducted at admission with all potential clinically significant medication issues identified during care and followed-up with a physician or physician designee. The numerator is the number of short-stay residents with an MDS 3.0 assessment during the selected time window for which all the following are each true:
- The facility conducted a drug regimen review at the admission (N2001= [0,1]) or resident is not taking any medications (N2001= ); and
- If potential clinically significant medication issues were identified at the admission (N2001 = ), then the facility contacted a physician (or physician-designee) by midnight of the next calendar day and completed prescribed/recommended actions in response to the identified issues (N2003= ); and
- The facility contacted a physician (or physician-designee) and completed prescribed/recommended actions by midnight of the next calendar day each time potential clinically significant medication issues were identified since the admission (N2005 = ) or no potential clinically significant medications issues were identified since the admission (N2005 = ). This condition is evaluated at discharge.
- Even though the roll-out is for October 1 this information will pertain to any new admissions or readmissions last week September with an ARD on or after October 1?
N2001. Drug Regimen Review - Complete only if A0310B = 01 (5-day PPS Assessment). This item is completed if one or more potential or actual clinically significant medication issues were identified during the admission drug regimen review (N2001 = 1). This item is effective on October 1, an admission late September may have an ARD early in October and use this item set.
- Section N new items - is there a specified look-back period? or does the standard 7-day look back applies?
Complete a drug regimen review upon admission (start of SNF PPS stay) or as close to the actual time of admission as possible to identify any potential or actual clinically significant medication issues.