Section G (Functional Status): CMS has added four new bullet points to the Coding Tips and Special Populations section for G0110 (Activities of Daily Living (ADL) Assistance):
Some residents are transferred between surfaces, including to and from the bed, chair, and wheelchair, by staff, using a full-body mechanical lift. If the resident holds onto a bar, strap, or other device during the full-body mechanical lift transfer is not part of the transfer activity and should not be considered as resident participation in a transfer.
The MDS Focused Survey purpose is to assess Minimum Data Set, Version 3.0 (MDS 3.0) coding practices and the relationship of that coding to resident care in nursing homes. Since the surveyor training began in early April 2015, an increasing number of SNFs have experienced this unique type of survey. The SNF experience with this new type of survey have been positive, and most providers felt it was an informative and helpful process.
ADL documentation is a critical component in capturing an accurate and appropriate rate of reimbursement for services rendered. Both Medicare (PPS RUG) and Medicaid (MMQ) use ADL assistance provided to generate a rate for reimbursement. Although both systems utilize ADL data, definitions and levels of assistance provided are different. Skilled Nursing Facilities often struggle to capture an accurate picture of the care provided for both Medicare and Medicaid.
Uncertainty. That is the word that best defines our country at the present time. The Supreme Court upheld Obamacare in June 2012, which again magnifies the significance of healthcare decisions for providers. Think about it. This decision continues to impact every organization, employer, employee, i.e., person in the United States. This impacts one of the largest sectors of the world’s largest economy.
Today we will be discussing the Medicare meeting, otherwise known as the beneficiary review meeting. This meeting is set up so that the interdisciplinary team can discuss the clinical status of a patient and whether that patient continues to meet the criteria for skilling under their Medicare Part A benefit. This meeting provides an opportune time to review the Medicare Part B beneficiaries or your managed care patients during this meeting. The goal of the meeting is not to focus on when the patient is going to be discharged. This is not a discharge planning meeting, the meeting is designed to review what the skilling criteria or the needs on a daily basis of the patient from nursing and from therapy. HHI recommends that the entire interdisciplinary team attend this meeting and that each member of the team be aware of what they are going to be reporting on during the meeting. For example, the business office would be discussing how many days the patient has used in their benefit period or how many days the patient has left. MDS may be discussing what the potential selected ARD date is. As well, MDS may discuss ADL assistance provided to the patient to make sure that team members are in agreement with the level of assistance provided to assure levels are accurately reflected on the MDS. Nursing should be talking about why the patient requires daily skilled care and therapy should talk about the patient’s status in relationship to their ability to continue to provide daily skilled care to the patient. Again, this meeting is so that the team can assure that the facility is accurately utilizing the patient’s Medicare Part A benefit.
The SNF PPS FY2012 Final Rule (76 FR 48486) outlined several policy changes in the SNF PPS effective for FY 2012. These changes include: a revised MDS assessment schedule, the Change of Therapy (COT) Other Medicare Required Assessment (OMRA), a resumption of therapy option for the End-of-Therapy OMRA, the allocation of group therapy time, and a revised student supervision policy. CMS has posted a transition document for implementation of these changes scheduled for October 1, 2011.
SNF Leaders do not have a long lead time between July 27 and October 1 when SNF PPS changes posted in the Final Rule go into effect. The next two months will be filled with reading and re-reading the SNF PPS Final Rule, working on assimilating and interpreting the planned changes as well as participating in the CMS ODFs and web education to confirm each facet of this complex reimbursement program. Language in the Final Rule regarding MDS 3.0 guidance, billing allowances and documentation requirements can easily be misinterpreted.