FY 2022 RAI Manual Updates? Yes Indeed!

Well, it’s FY 2022! And you thought here would be no changes to the RAI Manual this year. Think again! One has been made. Late last week CMS quietly posted the following announcement to the MDS 3.0 website.

The PDF file labeled “MDS3.0RAIManualv1.17.1R.Errata.October.1.2021,” contains revisions to pages in Chapter 6 of the MDS 3.0 RAI Manual v1.17.1R that update the NTA Comorbidity Score Calculation table. Changed manual pages are marked with the footer “October 2019 (R).”

The errata document begins with a table that lists all identified revisions and the pages to which they have been applied. Following the table are the actual corrected replacement pages for insertion into the printed manual.

Now, in all fairness, some of us knew this was going to happen, we just didn’t know when. CMS posted the following announcement to the MDS 3.0 Technical Information website on Sept. 21st. CMS also indicated that there would be a forthcoming errata document to address the RAI Manual revision necessitated by this issue.

Also, the note regarding logic updates to the NTA Comorbidity Score Calculation for the MDS 1040 Items refers to a change in the GROUPER logic that was made in January 2021 to correct a technical error that allowed two points to be added to the total NTA score instead of one point as originally intended by the PDPM coding logic. While this technical error affected very few stays (0.075%) from October 2019 to December 2020, a description of the logic change was not included in the documentation when the revised GROUPER DLL was posted in January 2021.  The coding logic contained in the current production GROUPER since January 2021 and in the Java GROUPER that is effective October 2021 should be utilized from this point forward.

The errata document was finally posted with little fanfare on Friday Oct. 1st. The issues addressed in the errata document have been known for some time and have been communicated to CMS. The issue has to do with the NTA items M1040A, M1040B and M1040C. In the original PDPM grouper that was detailed in Chapter 6 of the RAI Manual v1.17.1, These items were listed as affecting the NTA category as follows.

Apparently, CMS never intended for M1040B to contribute a separate NTA point. And, in January 2021, CMS released a DLL package that corrected the issue with no “public” announcement that this had been done. Consequently, myself some of my collegues received calls over the last year related to facilities not receiving the full 2 points the original grouper indicated were available and we chalked it up to a glitch in the grouper. And communicated this to CMS.

Fast forward to today and voila, CMS, has corrected the issue, “publicly”. The errata documented posted last week indicates, “…any, a combination, or all of Items M1040A, M1040B, and M1040C add one point consistent with the current PDPM GROUPER”.  The update to Chapter 6 of the RAI Manual is also included in the errata document. While this change is effective Oct. 1, 2021, as of this morning, there has been no update to the RAI manual posted at the MDS 3.0 website, only the errata document has been posted.

I recognize that a relatively few stays, (0.075% from October 2019 to December 2020), were affected by this issue. However, in my limited scope of influence, I know of at least three cases where this occurred. So be aware of these changes and replace pages 6-30 and 6-31 in your RAI Manuals with the revised pages from the errata document. Don’t get caught off guard thinking you deserve 2 NTA points surrounding these items when CMS has finally clarified that you will only receive 1.

PDPM Navigator® users should expect an update shortly.