Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
Section GG is causing a tidal wave of questions and has the Harmony HealthCARE Specialists working around the clock. While there are elaborate answers and references to the CMS website, industry experts and discussion groups, here is a distilled Q and A we hope you find useful.
- When is the data collection period?
- The data collection period is within the first 3 days of the most recent Medicare Part A Stay.
- Before therapeutic interventions are initiated. Be mindful, a therapist treats during an evaluation, so this data must be obtained before therapy interventions or treatment. (RAI manual p.295). “In order to capture the resident’s true admission baseline status.”
- Hence, if therapy treats on day two, day three will not be included in the observation period.
- Please note, the data collection period could be minimized. For example, one half of the day of admission can only be used as the data collection period if the therapy treatment is initiated at noon on the day of admission.
- Is there a separate ARD for section GG?
- No, there is not a separate ARD for Section GG.
- The ARD is the same as the 5-day assessment, days 1-8.
- There is a difference between ARD and Collection Period.
- The collection period is the “look back period” or “observation period”. (Similar, to when coding depression, the look back period is the last 14 days from the date of interview. With Section GG, the look back period is 3 days from admission before therapy treatment).
- When do I complete Section GG?
- Section GG is completed at the beginning and the End of the Medicare Stay. (The End of the Medicare Stay Assessment is called NPE-Nursing Home PPS End).
- More Specifically:
- Medicare Admission or Reentry with the associated 5 day MDS,
- And a planned discharge, or
- the end of a Medicare Stay
- The information needs to be entered into the software program or onto the paper MDS (per facility policy) the day it was collected/completed or within the regulatory time frames of completing the MDS Assessment.
- When is Section GG NOT completed?
- Section GG is NOT completed with a Medicare Stay less than 3 days or unplanned discharge.
- An unplanned discharge is defined as:
- AMA (Against Medical Advice),
- Leave before established and planned discharge date, or an
- Acute hospital transfer.
- What is a dash?
- A dash indicates no information or not assessed.
- When is a dash used?
- CMS indicates that a dash for the resident’s performance should be a rare occurrence.
- A dash may be used on discharge goals after at least one goal has been established.
- The use of dashes for the admission and discharge performance may result in payment reduction for not reporting. (QRP).
- When do I complete goals for Section GG?
- Complete goals for Section GG on the 5-day admission/reentry assessment.
- These goals reflect the expected level of performance of the resident when they leave the facility or the end of their Medicare Stay.
- 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. (RAI manual p.295).
- How many goals do I need to complete?
- The requirement is that at least one goal is established for the entire Section GG.
- We are hearing that many software programs are forcing the end user to complete all goals. In these instances, contact your software provider or check the facility settings in the software program.
- When should therapy be involved for Section GG?
- Therapy should be involved on Admission with the Performance Status upon Evaluation and Therapeutic Intervention and Goal Setting.
- Therapy should be involved on Discharge or the End of the Medicare Stay with Performance Status if therapy is still actively treating.
- Nursing needs to determine above if therapy not involved.
- Do I complete Section GG for residents admitted prior to October 1, 2016?
- Yes, complete Section GG for residents admitted prior to October 1, 2016.
- If the 5-day ARD is 10/1/16 or later.
- And/or the Discharge or the End of the Medicare Stay ARD is 10/1/16 or later.
- The Rejected MDS may be the result of opening an MDS prior to the new software updates. In these instances, correct and resubmit the MDS.
We hope this blog post helps you and your staff with understanding the complexities of Section GG. There is a significant amount of confusion due to its newness and parallel requirement with section G. We will be discussing Section GG in detail at harmony16: Our Annual LTPAC Interdisciplinary Symposium, November 4-5 2016 at Foxwoods Resort in Ledyard, CT.Harmony Healthcare International (HHI) is available to provide onsite analysis and associated medical record reviews to help you improve your Quality Measure Scores. Please contact Harmony Healthcare International by clicking here or calling our office at 1.800.530.4413.
5th Annual LTPAC Symposium
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