This week, CMS surprised us with a revised version of the MDS that will be effective this fall for FY 2021. It is a surprise because nothing about this particular change was mentioned in the proposed rule posted in April.
CMS has indicated in the May posting on the MDS Technical Information page that in response to State Medicaid Agency and stakeholder requests, they have updated the MDS 3.0 item sets with changes that will support the calculation of PDPM payment codes on OBRA assessments that are not combined with the 5-day SNF PPS assessment. This is a logical lead up to the planned elimination of section G that was slated to take place this fall but has been postponed until 2 years following the current COVID-19 situation.
Specifically affected are the OBRA comprehensive (NC) and OBRA quarterly (NQ) assessment item sets. Calculation of PDPM payment codes is not possible with the current item set version 1.17.1. CMS indicates that these revisions will allow State Medicaid Agencies to collect and compare RUG-III/IV payment codes to PDPM ones and thereby inform possible future Medicaid payment models.
The major caveat that CMS included with this message is that providers should confirm with their State Medicaid Agency to find out if their State will be requiring the calculation of the PDPM payment codes on OBRA assessments that are not combined with a 5-day SNF PPS assessment. This will be important to know come October 1st.
That said, what exactly changed? If you take a look at the revised Comprehensive data set it is still 51 pages and the revised Quarterly data set is still 45 pages. Also, we don’t have a revised RAI Manual yet so where do we go to locate the change?
Included in the downloaded zip file that you can access at the link noted above, you will find a change table that details the revisions that will occur. The updates are centered around items that will be activated on these assessments that will allow for PDPM calculation when these assessments are not combined with a 5-day PPS assessment.
Section I and J revisions in, particular, refer to these items in reference to the post-acute period after a recent hospital stay. Either the states or the RAI Manual will need to offer further guidance as to how these items will apply to long term patients. Here is a list of the items you should pay attention to.
1. The footer has changed as it always does with an update. However, Since the changes to the new version are hard to spot, ensuring that you are using the correct version will be essential.
2. Section GG: Items GG0130 and GG0170 Headers have been changed to read “Start of SNF Stay or State PDPM”, and new completion instructions include, “If state requires completion with an OBRA assessment, the assessment period is the ARD plus 2 previous days; complete only column 1.)”.
3. Section I: Item I0020 instructions for completion have been revised to read, “Complete only if A0310B = 01 or if state requires completion with an OBRA assessment”.
4. Section J: Item J2100 instructions for completion have been revised to indicate, “Complete only if A0310B = 01 or if state requires completion with an OBRA assessment.
We are all thankful that these item revisions are not as comprehensive as revisions to the MDS have been in the past. However, if your state wants to compare RUG data to PDPM data as a consideration for amending Medicaid reimbursement mechanisms, then the revised guidelines will need to be followed.
Do not wait until October to ask your state whether they will require PDPM data to be tabulated with completion of Comprehensive and Quarterly assessments. With this revision, getting ready for October begins now. Contact your state Medicaid office soon to find out what they will require.
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