Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
MDS 3.0 Section GG has proven to complicate matters when it comes to coding the MDS. Daily calls inquiring how to interpret the regulations consumes the Harmony Healthcare International (HHI) phone lines and HarmonyHelp Client Only Knowledge Center.
One of the most frequently asked Section GG questions to date is:
“What is the ideal number of goals that should be addressed in Section GG?”
The Harmony Healthcare Team believes the “ideal number of goals” to address in section GG is dependent upon the individualized resident situation and there is no “cookie cutter” answer to this question.
The RAI Manual provides the following with respect to discharge goals:
- Licensed clinicians can establish a resident’s discharge goal(s) at the time of admission based on the 5-Day PPS assessment, discussions with the resident and family, professional judgment, and the professional’s standard of practice.
- Goals should be established as part of the resident’s care plan.
- Discharge goals may be determined based on the resident’s admission functional status, prior functioning, medical conditions/comorbidities, discussions with the resident and family, and the clinician’s consideration of expected treatments, and resident’s motivation to improve.
- For the QRP Function Measure, the Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function, a minimum of one self-care or mobility goal must be coded per resident stay on the PPS 5-Day assessment. A SNF’s Annual Payment Update will not be affected if at least one self-care or mobility goal is submitted.
- Providers are free to include as many goals as they deem appropriate.
Harmony Healthcare International (HHI) recommends the following process when reviewing records for the resident specific approach using :
- First, review the assessment column to verify that it is supported by the clinical documentation in the record.
- Review the plan of care to determine what discharge goals have been established by the clinician at the time of admission in the therapy plan of care or baseline care (required within 48 hours of admission by the RoP).
The Harmony Team has seen Providers code goals in section GG for each and every self-care and mobility item to avoid the use of dashes. In many situations, this would not be appropriate because a goal for a particular item is not established when the patient is currently functioning at the prior level of function and there is no concern that loss of function may occur. The most common examples would be eating and oral hygiene. If the patient is already independent in these areas at baseline and no improvement or maintenance goals have been established as part of the care plan/plan of care then no goal should be coded in Section GG and the MDS would be appropriate dashed in these areas.
The Harmony Team has also seen Providers dash all goals except one. This is because one goal is all that is required and the Provider “does not want to do more than what is required for fear of sending red flags when goals are not achieved.” In most cases, they are unable to explain how or why they chose the area they did to set the goal. Some therapists liken it to the G codes for Medicare Part B where you are only allowed to report one goal at a time. The Harmony Team encourages Providers to review the care plan and code the goals in section GG based on the discharge goals established as the long term goals for therapy.
When a patient is receiving both occupational therapy (focused on self care tasks) and physical therapy (focused on mobility), we encourage Providers to set at least one goal for each discipline based on the focus of their plan of care.
One last comment is with respect to walking. This question has a skip criteria based on the response to the “gateway” question of “Does the resident walk?” If the response to this question is “No and a walking goal is clinically indicated,” the expectation is that a goal would be established for one of the walking items (unless the goal is for distance). For example, bed to toilet or other distance less than 50 feet with two turns.
When reviewing the MDS, if the response is as noted above and both walking goals are dashed, it is advised to review the PT Evaluation and Plan of Care to determine how walking is addressed. Specifically, “how far did they patient ambulate at the PLOF, current level and what discharge goals have been established for ambulation”. The coding of section GG for this item should be consistent with the clinical documentation. Walking is the area in section GG where Harmony Healthcare International (HHI) finds that the facility staff have most confusion and need for clarification.
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