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CMS is delaying the release of the revised MDS 3.0, which was scheduled for October 1, 2020. CMS updated the minimum data sets of the MDS 3.0 to support the calculation of PDPM Payment for OBRA Assessments that are not combined with a Medicare Part A 5-Day PPS Assessment.
The revised MDS will allow states to:
- Calculate PDPM Payment Codes for OBRA Assessments.
- The option to compare RUG-III/RUG-IV with PDPM Payment Codes to provide insight on the impact of a future with PDPM Medicaid state payment methodology.
Many states are transitioning to the PDPM Medicaid platform as their methodology for Medicaid reimbursement. The attached map (download) depicts the current states that use MDS Case Mix for Medicaid reimbursement and the states that are currently collecting (purple) PDPM Billing Codes on their regulatory (OBRA) MDS assessments.
The forthcoming MDS updates are geared towards utilizing the same MDS base for both PDPM and regulatory assessments, i.e., OBRA assessments and PPS assessments. Sections specifically revised:
- Section GG (Functional Abilities and Goals),
- Section I (Active Diagnoses), and
- Section J (Health Conditions).
Section GG (Functional Abilities and Goals):
Section GG will now be used for OBRA assessments as well as Medicare Part A PDPM. The item headers have been updated to reflect the proper nomenclature, i.e., Functional Abilities and Goals, Start of SNF PPS Stay or State PDPM.
Even though the origin of the MDS tool in 1987 was created as an “assessment” tool i.e., a source document, the evolution of payment derived from the MDS has created the need for supporting documentation in other areas of the medical record.
Hence, documentation to support the coding of Section GG is required.
- For Medicare Part A Patients, it remains the first 3 days of the stay and the last 3 days of the stay.
- For OBRA assessments, it will be the ARD, and the two preceding days and no discharge data will be required.
It is prudent to review the facility’s process for collecting data for the accurate coding of Section GG. There will be less flexibility with ARD Management and supporting documentation is required for 3 days regarding each item on the MDS. It is important for the team to review who is going to be “assessing each” item and determine how the team will decide on the patient’s “usual performance.” This method of determination should also be documented to support MDS coding.
Section GG reflects the “usual performance” of the resident over a “three-day period,” over all shifts.
Section I (Active Diagnoses):
Will include item I0020, the resident’s primary medical condition category. The facility to complete only if A0310B = 1 (PPS 5-day assessment), or if the state requires completion with an OBRA assessment. The facility level team should determine how this diagnosis will be chosen and coded.
Section J (Health Conditions):
J2100, revised to Recent Surgery Requiring Active SNF Care – Complete on if A0310B = 1 or if the state requires completion with an OBRA assessment.
- For Medicare Part A Patients, code surgery that occurred during the inpatient hospital stay that immediately preceded the resident’s Medicare Part A admission.
- For OBRA assessments, code surgery that occurred within 30 days preceding the ARD of the OBRA assessment.
Click below to learn more about Harmony Healthcare International (HHI) 3-day virtual MDS Competency Program CHHi-MDS course offering participants a more comprehensive understanding of the RAI process. It will be held on October 13th, 14th and 15th.