Providers have long struggled with items that may not be modified on the MDS 3.0 assessment. Occasionally, a typographical or data entry error will cause an assessment to be submitted with the ARD entered incorrectly in section A2300. Providers only option was to inactivate the assessment with the error and complete a new assessment when the error was discovered with the current date as the ARD. If the resident was no longer covered under Medicare Part A when the error was discovered the facility would be unable to replace the inactivated assessment.
Beginning on May 19, 2013, providers will have the option to modify this item on the MDS. Providers will be able to modify the assessment to correct an error in the ARD field, provided the assessment “look back” period does not change by altering the ARD. The ability to modify the ARD on an assessment that is otherwise valid eliminates financial penalties that resulted under the previous policy, which required the assessment be inactivated resulting in a late or missed assessment. Modifying the assessment would enable the facility to appropriately bill the HIPPS code generated for the number of day covered by the assessment type.
Listed below are some examples of situations in which the Modification of the ARD would be allowed if an error is identified subsequent to the assessment being accepted in the QIES database:
- The ARD could be appropriately modified when an assessment was completed and submitted to the QIES ASAP based on the ARD of 04/05/13 although section A2300 was incorrectly coded “05/04/13” due to a transcription error. In this case, the MDS was accurately completed and coded to reflect the clinical status of the resident on 05/04/13 not 04/05/13. A modification would be the appropriate corrective action.
- Similarly, if the provider correctly completed the 5 day MDS based the selection of day six as the ARD but incorrectly entered the admission date as the ARD in section A2300, the “look back” for the assessment is based on day six, and not the admission date. This clerical error in the ARD field could be corrected utilizing the modification process since the correction would not alter the “look back”
- Another situation in which the ARD may be entered incorrectly could occur when the MDS is initially opened with an ARD of day 6 and the IDT elects to move the ARD to day 8 to better reflect the services provided. The MDS is accurately coded based on the selection of day 8 as the ARD, but the MDS Coordinator forgets to change the ARD in the system/computer prior to transmission. In this case since the MDS is correctly coded based on the ARD of day 8, correcting the ARD will not change the “look back” period. This type of error should be corrected utilizing the modification process.
The ability to correct an incorrectly coded ARD utilizing the MDS Modification process will not change the current requirements that limit the provider’s ability to move the ARD of an MDS. As outlined in Chapter 3 of the RAI User’s manual, CMS requires the ARD for an MDS to be set on the MDS form itself during the allowable “window” for the ARD. The ARD may be moved if the facility chooses to select the date that best reflects the care and services the patient needs and will receive, but this can only occur while the assessment “window” is open. Once the assessment “window” has closed, it is no longer permissible to move the ARD established. For example, the window for ARD selection for the 5 day Medicare MDS is days 1 through 8 including grace days. The ARD for this assessment therefore must be established on the MDS on or before the end of the eighth day of the stay. If the facility initially sets day 5 of the stay as the ARD for this MDS, they may decide to move the ARD to a later day to capture more therapy minutes in the “look-back”. This decision cannot be made on or after day 9 of the stay because the assessment window is no longer open.
One example in which a modification would not be allowed to change the ARD is when the MDS is correctly coded and completed based on the selection of day 5 of the stay and the team determines post submission that the selection of day 8 would result in an enhanced RUG score since a greater number of therapy minutes would be captured on the MDS.
In this case, since modifying the ARD would alter the assessment “look back” period a modification would not be allowed.
Providers are encouraged to maintain good practices, such as the use of the 7 day encoding period, to keep these corrections to a minimum. Good communication between disciplines will decrease transcription errors of ARDs, and will ensure that patients receive the best care.
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