Harmony Healthcare Blog

RCS-1 (Resident Classification System): Significant Change in Status Assessments

Posted by Kris Mastrangelo, OTR/L, LNHA, MBA on Tue, Jul 11, 2017

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Edited by Kris Mastrangelo

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


questions.jpgThe proposed RCS-1  (Resident Classification System) Payment System is creating waves of questions and comparisons to the existing system. Each element leads to hours of discussion in a rabbit hole type of path.  In true Harmony Healthcare International (HHI) fashion, we like to distill and synthesize without drama or delay.  An important point to address today in preparation for tomorrow is the Significant Change in Status Assessment Criterion. 

Why you ask?  Because in the proposed payment system, an SCSA will be the only way the payment level will change after the initial assessment.

If the Facility Staff do not have a proper understanding of the rationale for completing this assessment, the facility may be improperly reimbursed for the services provided.

The criteria for completing a Significant Change in Status Assessment (SCSA) as outlined in the MDS 3.0 RAI User’s Manual is as follows: 

  • Facilities have an ongoing responsibility to assess resident status and intervene to assist the resident to meet his or her highest practicable level of physical, mental and psychological well-being.  Decline is not an expected process of aging, it is a product of diseases or conditions, of which with appropriate intervention loss can be minimized. 
  • A SCSA is not required in a case where the resident’s condition is expected to return to baseline within a short period, such as one to two weeks.  If the condition does not return to baseline, the assessment should be completed as soon as needed to provide appropriate care to the resident, but no later than 14 days after the determination was made that a significant change occurred. 
  • A “Significant Change” is a decline or improvement in a resident’s status that:
    1. Will not normally resolve itself without intervention by staff or by implementing standard disease-related clinical interventions, is not “self-limiting”
    2. Impacts more than one area of the resident’s health status; and
    3. Requires interdisciplinary review and/or revision of the Care Plan. 
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  • A SCSA is appropriate if there are either two or more areas of decline or two or more areas of improvement.  Note that if there is only one change, staff may still decide that the resident would benefit from an SCSA.  It is important to note that resident’s situation is unique and the interdisciplinary treatment team must make the decision as to whether the resident will benefit from the completion of a comprehensive assessment. 
  • A SCSA is required to be performed when a terminally ill resident enrolls in a hospice program (Medicare Hospice or other structured hospice) and remains a resident at the nursing home. The ARD must be within 14 days from the effective date of the hospice election (which can be the same or later than the date of the hospice election statement, but not earlier than). A SCSA must be performed regardless of whether an assessment was recently conducted on the resident. This is to ensure a coordinated plan of care between the hospice and nursing home is in place. 
  • A SCSA is also required to be performed when hospice services are terminated. The SCSA must be completed within 14 days from one of the following:
    1. The effective date of the hospice election revocation;
    2. The expiration date of the certification of terminal illness; or
    3. The date of the physician’s or medical director’s order stating the resident is no longer terminally ill.
The final decision regarding what constitutes a significant change in status must be based upon the judgment of the clinical staff and the guidelines below. (Not an exhaustive list):

Decline in two or more of the following: 

  • Resident’s decision making changes from 0 or 1 to 2 or 3 for Item B4;
  • Emergence of sad or anxious mood pattern as a problem that is not easily altered;
  • Increase in the number of areas where Behavioral Symptoms are coded as “not easily altered”;
  • Any decline in ADL physical functioning area where a resident is newly coded as 3,4, or 8;
  • Residents incontinence pattern changes or there was placement of an indwelling catheter;
  • Emergence of a pressure ulcer at Stage II or higher, when no pressure ulcers were previously present at Stage II or higher;
  • Resident begins to use trunk restrain or a chair that prevents rising when it was not used before;
  • Overall deterioration of a resident’s condition; resident receives more support;
  • Emergence of a condition or disease in which a resident is judges to be unstable. 

Note that patients with improvements in the above noted areas are to be reviewed for SCSA for improvement. 

After the above is all said and done, the team must remember one very important component: 

“If the team feels that the patient’s condition requires the interdisciplinary review and management necessary to refine the care plan, then the completion of a significant change in status assessment is warranted.”

Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have regarding regulatory changes.  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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