Providers sought clarification on the correct coding of MDS 3.0 item G0110: Activities of Daily Living (ADL) Assistance, Column 1: Self Performance. CMS has delivered.
CMS presents the following scenario to providers:
Supervision occurred five times in the look back period, while Limited Assistance occurred twice, and Extensive Assistance and Total Assistance each occurred once.
In this scenario, the correct code for G01101 would be "1" indicating Supervision, because there were not three or more instances of a single higher level.
The rationale for this decision is that the resident received more than three episodes of supervision in the look back period, as well as three or more episodes of a combination of full staff performance, weight-bearing assistance, and/or limited assistance; but not three times at any one of these levels. Because the threshold of three or more times of Supervision was met, and there were not three or more instances of a single higher level, the correct code in such a scenario would be "1" indicating Supervision.
This update is anticipated to be incorporated in the May 2013 update to the RAI User's Manual. CMS reported they will be updating coding instructions, as well as the ADL Algorithm on page G-6 of the Manual. These updates are not yet publicly available.
Providers have expressed concern about this clarification, as the overall coding in Section G of the MDS may not be an accurate representation of the resident's status. Providers are concerned that the MDS 3.0 assessment may not provide as accurate a picture of the resident, and therefore a less relevant care plan, under these new coding clarifications.
Harmony (HHI) stresses the importance of documentation each time care is provided. This practice will ensure capture of every instance of the higher level of care provided in order to code the most accurate level of assistance on the MDS. Harmony (HHI) stands by the value of staff education leading to increased clinical accuracy, and therefore to clinically appropriate reimbursement.
The scenario for coding supervision when limited and extensive assistance occurred less than three times should be a rare occurrence, and if seen frequently, should be a focus of investigation by facility managers.
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