The time has come to finalize all training and determine how your facility will capture the most accurate data for coding in the new Section GG of the MDS 3.0 to be implemented in October. The draft manual provides insight for providers regarding the coding guidance. Additionally, CMS provided two days of training June 21st and June 22nd including a live broadcast to give providers an opportunity to hear firsthand how these changes to the MDS will unfold. This new section of the MDS allows the assessor to provide additional depth in reporting functional performance with eating, oral hygiene, toilet hygiene as well as mobility. The big, heavy pressing question is WHO will be responsible at the facility for gathering and coding this information? Many providers say that their knee jerk reaction is to have the rehabilitation professionals assess and code these new items. While this may work for some providers, this same approach may not be advantageous for all skilled nursing facilities.
Questions to consider:
- Who will train the team with emphasis on Steps for Assessment from the RAI “draft” Manual which provides guidance that the status is based on direct observation, resident’s report, family report and documentation of direct staff.
- Has the team discussed the definition of “usual performance”?
- How will the data be collected? Will a form be developed or will the team verbally discuss?
- Is the MDSC going to be a liaison between nursing assessments of function and rehabilitation professionals reporting of “usual performance”?
- Does the team meet regularly to review the RAI Manual examples of coding Section GG to confirm that the staff in the facility is consistent with the coding?
- Does the team report the 6 point coding scale with consistency to maintain the inter-rater reliability?
- Supervision OR Touching
- Partial/moderate assistance: Helper does Less Than Half the effort.
- Substantial/maximal assistance: Helper does More Than Half the effort.
More things to ponder….providers should be mindful that the scoring of Supervision, Moderate and Maximal assistance as defined above are not consistent with how therapies assess and report functional performance on their standard evaluations.
A significant concern for providers will be how this Section GG will eventually impact the New Quality Measures for Short and Long stay tied to MDS based functional measures. The following QMs will be directed impacted by coding in Section G.
- Percent of Residents Who Improved Performance in Transfer, Locomotion, and Walking in the Corridor (Short Stay), and
- Percent of Residents Who Declined in Independence in Locomotion (Long Stay), and
- Percent of Residents Whose Need for Help with Activities of Daily Living Increased (Long Stay).
The four late loss ADLs in Section G have been a major focus for providers to maintain accuracy with documentation, observations and coding. There are now additional areas in Section G and Section GG that will demand further scrutiny and education for direct care staff to avoid miscoding resulting in disruption in the Quality Measures as well as impacts to reimbursement under Prospective Payment and Case Mix.
Preparation for providers will include dedicated time to educate the entire interdisciplinary team as well as the patient and family for clarity with performance levels in the following tasks:
- Eating – bringing food to the mouth AND swallowing
- Oral Hygiene – management and cleaning of dentures is considered
- Toilet Hygiene and toilet transfers – Managing ostomy is assessed here, but not managing the equipment. (Is the team clear on this?)
- Lying to sitting and sit to stand
- Walking and wheelchair mobility a minimum of 50 feet with two turns incorporated – Does the facility have a suitable space to assess the patient turning in the wheelchair?
Once the performance of the patient based on the 6 point coding scale has been determined, the team will be required to settle on which area(s) will result in discharge goals being set. With MDS focused survey expanding throughout the country, precision with MDS coding should be at the top of the priority list.
If you have questions about Section GG, please contact Harmony Healthcare International by clicking here or calling our office at 1.800.530.4413.
5th Annual LTPAC Symposium
Featuring Guest Speaker Julia Fox Garrison
Click Here to Register