Harmony Healthcare Blog

Combining OBRA and PPS MDS Assessments

Posted by The Harmony Team on Tue, Aug 01, 2017


Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency

Puzzle-Assessment.jpgIt is common practice to combine the OBRA Admission Assessment with the PPS 5-Day or 14-Day Assessment when the time frames coincide for both required assessments.  This is allowable to avoid unnecessary duplication of effort.  In such cases, the most stringent requirement of the two assessments for MDS completion must be met. In addition, one assessment may satisfy two OBRA assessment requirements, such as and Admission and Discharge Assessment, or two PPS Assessments, such as a 30-Day Assessment and an End of Therapy OMRA. 

The OBRA Admission Assessment is a comprehensive assessment for new residents and, under some circumstances, returning residents.  Requirements include:                                                                

  • Completed (with CAAs)
  • Completed by the end of day 14, counting the date of admission to the nursing home as day 1.
  • The ARD (Item A2300) must be set no later than day 14.
  • The MDS completion date (Item Z0500B) the CAA(s) completion date (Item V0200B2) must be no later than day 14.
  • The Care Plan completion date (Item V0200C2) must be no later than 7 calendar days after the CAA(s) completion date (Item V0200B2) (CAA(s) completion date + 7 calendar days). 

Download HHI's Medicare Scheduled and Unscheduled MDS Assessment  ARD ScheduleSeeing that the ARD requirements for the PPS 5-Day Assessment include days 1-8 and the PPS 14-Day Assessment include days 13-18, the OBRA Admission Assessment may be combined with either PPS Assessment.  However, be aware! The appropriate ARD selection must meet both OBRA and PPS Assessment requirements. 

  1. Therefore, when the OBRA Admission Assessment is combined with the PPS 5-Day Assessment, all allowable ARDs may be selected (days 1-8). 
  1. However, when the OBRA Admission Assessment is combined with the 14-Day Assessment, only ARD day 13 or 14 is allowable. This eliminates the use of days 15 through 18 for the 14-Day PPS Assessment. In addition, use of day 13 or 14 for the ARD reduces the completion time frame to 1 day (with CAAs). 

In some instances, a later ARD for the 14-Day PPS Assessment may be optimal to combine a COT with a 14-Day.  On other occasions, a later ARD for the 14-Day PPS Assessment may be optimal to better reflect ADL assist provided later in the ARD period. 

Oftentimes, the OBRA Admission Assessment is combined with the 14-Day PPS Assessment due to a concern that unnecessary comprehensive assessments are completed when a patient is discharged prior to day 14. If the patient has a planned stay of less than 14 days, you should not combine the PPS 5-Day Assessment with the OBRA Admission Assessment. If a patient experiences an unplanned discharge (likely to acute) and return is expected, the Admission Assessment requirement is met and another Admission Assessment is not required. 

Harmony Healthcare International (HHI) recommends combining the OBRA Admission Assessment for admissions with a planned stay that is greater than 14 days. 

Harmony Healthcare International (HHI) notes the transmission requirements for MDS assessments completed on the PPS schedule for Managed Care. Facilities are expected to transmit OBRA required, PPS MDS assessments and tracking to the CMS Quality Improvement Evaluation System (QIES). 

Do not submit MDS Assessments that are completed for purposes other than OBRA or Medicare.  For example, private insurance, Medicare Advantage, HMO’s. Harmony Healthcare International (HHI) emphasizes the importance of ensuring that all MDS Assessments completed for Medicare (PPS) are transmitted per the RAI requirements and prior to billing Medicare. 

A2400A, “Has the Resident Had a Medicare-covered Stay since the Most Recent Entry” should only be complete when the Skilled Nursing Facility stay is billable to Medicare Part A. This does not include stays billable to Medicare Advantage HMO Plans. Therefore, A2400B/C, Medicare Start and End dates would also not be complete if the stay is not billable to Medicare Part A. Coding these items when not instructed will allow the QIES System to accept these assessments. 

Harmony Healthcare International (HHI) provides education in regards to the RAI User’s Manual requirements and the process to flag these assessments in the MDS software to prevent transmission. 


  1. Review Electronic Health Record  instructions to label Non-Traditional Medicare A PPS Assessments as “do not submit” for oversight.
  2. Ongoing monitoring through the facility’s Compliance/QAPI Program.
  3. Do not complete Medicare Start and End dates in section.

Harmony Healthcare International (HHI) is available to provide assistance You can contact us by clicking here.  Looking to train your staff?  Join us in person at one of our our upcoming Competency/Certification Courses.  Click here to see the dates and locations. 

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Topics: ARD Schedule, MDS Assessments

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