Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
Effective October 1st, Medicare requires a Medicare Part A PPS Discharge Assessment. This MDS contains the required data elements used to calculate current and future Skilled Nursing Facility Quality Reporting Program (SNF QRP) quality measures under the IMPACT Act. The IMPACT Act directs the Secretary to specify quality measures on which post-acute care (PAC) providers (which includes SNFs) are required to submit standardized patient assessment data. Section 1899B(2)(b)(1)(A)(B) of the Act delineates that patient assessment data must be submitted with respect to a resident’s admission to and discharge from a Medicare Part A Assessment.
Providers who fail to report data required for quality measures calculation will be subject to a 2%-point reduction in their market basket rate effective October 2018.
Compliance for completion of the Medicare Part A PPS Discharge Assessment
is critical to prevent a 2% reduction.
The top 5 questions surrounding this requirement include:
- What if a patient remains in the facility after their Medicare stay and another MDS is not required?
In situations where the patient remains in the facility after ending their Medicare stay (e.g. 100th Day, Change in Payor source) and no other OBRA or PPS MDS is required, the Medicare Part A PPS Discharge Assessment is still required. A standalone MDS is created in the MDS software by creating a MDS and coding in section A0310H “yes” and answering no for all PPS, OBRA and Discharge tracking questions. It is critical that facilities develop a plan to validate that these MDSs are completed. Although these MDSs due not impact billing, they will provide data that will impact the Medicare rate October 2018.
- When is this MDS Required?
The Medicare Part A PPS Discharge MDS is completed when a patient’s Medicare Part A stay ends:
- When the Medicare Part A stay ends and the patient remains in the facility
- When the Medicare Part A stay ends and the patient is physically discharged from the facility (the Part A PPS and OBRA Discharge assessments may be combined in this situation)
- Can I combine this Part A PPS Discharge Assessment with other MDSs?
The MDS is designated as a Medicare Part A PPS Discharge MDS in section A0310H by coding the question “Is this a Part A PPS Discharge Assessment?” as “Yes”. This MDS may be combined with other Scheduled PPS MDs (14 Day, 90 Day) or OBRA MDSs (e.g. Quarterly, Annual). CMS has clarified that in cases where an only an unscheduled PPS MDS (Change of Therapy (COT) MDS, End of Therapy (EOT)) is required with the same ARD as The Medicare Part A PPS Discharge assessment, these MDSs must not be combined and therefore must be completed separately. For example, when a COT with and ARD equal to the ARD of the Part A PPS Discharge Assessment is required they must be completed separately.
These MDSs (e.g. EOT, COT) may be combined with the Part A PPS Discharge Assessment only when they are also combined with Scheduled PPS MDs (14 Day, 90 Day) or OBRA MDSs (e.g. Quarterly, Annual).
- What ARD is used for the Part A PPS Discharge Assessment?
The end of Medicare date in section A2400C determines the ARD of the Part A PPS Discharge MDS. The ARD must be equal to the date recorded in section A2400C. The only exception is when the End Date of the Most Recent Medicare Stay (A2400C) occurs on the day of or day before the Discharge Date (A2000). In this situation the OBRA Discharge assessment and Part A PPS Discharge assessment are both required and may be combined with an ARD equal to the Discharge Date recorded in section A2000. This reduces redundancy by allowing these assessments be combined verses completing 2 separate MDSs.
Harmony Healthcare International (HHI) also emphasizes the importance of accurately coding the end of Medicare date in section A of the MDS. The end of Medicare date is coded as follows, whichever occurs first:
- Date SNF benefit exhausts (i.e., the 100th day of the benefit)
- Date of last day covered as recorded on the effective date from the Notice of Medicare Non-Coverage (NOMNC)
- The last paid day of Medicare A when payer source changes to another payer (regardless if the resident was moved to another bed or not)
- Date the resident was discharged from the facility (see Item A2000, Discharge Date)
- What happens if I do not complete this assessment?
Harmony Healthcare International (HHI) has noted a national trend of missing Medicare Part A PPS Discharge Assessments in situations where patients remain in the facility after ending Medicare Skilled Coverage. A system for monitoring compliance with these assessments is necessary to meet Skilled Nursing Facility Quality Reporting Program (SNF QRP). A missing Part A PPS Discharge Assessment is considering not reporting data.
Through our monthly auditing process, Harmony HealthCARE Specialists consistently identify missing Part A PPS Discharge MDSs. This occurrence is rampant and it is critical to schedule completion and provide education to the clinical team in order to correct and prevent future errors.
Again, providers who fail to report data required for quality measures calculation will be subject to a 2%-point reduction in their market basket rate effective FY2019 (October 2018 through September 30 2019).
Please contact Harmony Healthcare International (HHI) if you need help with your Medicare Part A PPS Discharge Assessments. You can contact harmony by clicking here or calling 800.530.4413.
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