T

he new changes to the Resident Assessment Instrument (RAI) manual became effective on June 15. So far, the changes have not caused too much commotion. Actually, most of the people we hear from seem to like the changes. Comments we have heard reflect a feeling that the changes make sense and are straightforward. But, as usual, there is much more going on the in the Minimum Data Set (MDS) world, making it difficult to keep up. We will try to provide our readers a rundown of the continuing changes. However, before the news report on the MDS world, we would like to answer some mail.
       "Dear Mabel: One of our Medicare Part A residents left the facility for a home visit during the assessment reference period for his 60-day Prospective Payment System (PPS) assessment. What should I do?” (registered nurse, Pa)
       Answer: This happens frequently. While it causes MDS coordinators gray hairs, it is perfectly legal and therapeutic for the resident. The Centers for Medicare and Medicaid Services (CMS) states that Medicare Part A residents may leave the facility for therapeutic reasons, such as a family reunion, anniversary, or holiday. The facility may not bill for days the resident is not in the building at midnight. Those days must be removed from the schedule and the bill. Sounds pretty simple, right?
       The difficulty occurs if the therapeutic leave days occur during the assessment reference period. Communication is key in dealing with this dilemma. Staff should be acquainted well enough with the resident to know when he or she is planning a therapeutic leave. That information must be communicated to the MDS coordinator. This will assist you in setting the assessment reference date (ARD). The days in the ARD must be consecutive. It does not matter if the resident is in the building or not; if the look-back period includes days the resident was out of the building, those days must be assessed, even though days out of the building will not be billed or counted in the schedule. Does that make sense? Probably not, but that is the way it is. So, it would be best to not schedule an assessment for which the look-back period falls during a therapeutic leave. You should alter your schedule to use only consecutive in-house days for the ARD. After all, how can you validate the activities of daily living (ADLs) or the medications administered if the resident is not there for you to assess and document your findings?

MDS News

       On a continual basis, CMS is reviewing and updating all federal Tags relating to the survey process for long-term care facilities. The goal is to review and update all Tags every 5 years. Coming in October is the new Section W. For this fairly straightforward section, CMS is trying to collect data on the use of flu and pneumonia vaccines in long-term care. In addition, CMS hopes to increase the number of residents receiving these vaccinations through increased awareness. Most software companies are already hard at work on this and have programs ready for the October launch date. Be sure to check with your vendor to be certain you will be up and ready for implementation.
       The new Resource Utilization Group (RUG) system is scheduled to start in January 2006. Do not be surprised if this is held up once or twice. Although CMS states there will be no effect on reimbursement, several stakeholders are not convinced. Discussion concerning the effect of these new expanded rehabilitation RUGs continues. To review this new proposed regulation, visit http://www.cms.hhs.gov/providers/snfpps//overview_fy06nprm.asp. The entire press release from CMS can be viewed at http://www.cms.hhs.gov/providers/snfpps/default.asp. Nine new rehabilitation RUGs have been added.
       There are also new computer upgrade requirements that must be met by December 31. These new requirements will enable facilities to access the new quality indicators and quality measures (QIs/QMs) and the error and submission reports. The requirements are as follows:
• Memory: 256 MB
• CPU: Pentium III, 500 MHz
• Hard drive: 500 MB free space
• Operating system: Windows 2000 or XP
• Browser: Internet Explorer v5.5, SP2.
For more information, visit http://www.cms.hhs.gov/medicaid/survey-cert/sc0522.pdf.
       And do not forget the newly rewritten Tag F315 on incontinence, which became effective on June 27. Although we are focused on the MDS, many of us realize that this F Tag could and should have a big effect on Section H of the MDS and on care planning. So, be sure to check it out at http://www.cms.hhs.gov/medicaid/survey-cert/sc0523.pdf.
       The Expedited Review Process has been the source of many questions about its use. We wish we had the answers, but we are awaiting the final word from CMS. If you would like to review the most current form, visit http://www.cms.hhs.gov/manuals /transmittals/comm_date_dsc.asp. Scroll down to June 3, 2005 and click on the “file” column, R577CP. The new expedited reviews became available on July 1, 2005 for beneficiaries in original Medicare whose Medicare-covered home health, hospice, skilled nursing facility (SNF), and comprehensive outpatient rehabilitation facility (CORF) care is being terminated, as we understand it at the time of this printing. For those who are interested in learning more, there is an article at http://www.cms.hhs.gov/medlearn/matters/mmarticles/2005/SE0538.pdf.
       Additionally, CMS announced plans for all providers in the Fee-for-Service Medicare programs to transition to a National Provider Identifier (NPI). This will be phased in gradually. If you do not have a NPI by May 23, 2007, your claims will not be processed. The next step will be to have that NPI on all forms processed by the federal government (ie, MDS submissions). We are still unsure about the exact process to obtain a NPI but are sure more will be forthcoming from CMS about this.
       Even though DAVE (Data Analysis Verification and Evaluation) is dead, we continue to hear from him. Two tip sheets have been released from DAVE. They are available at http://www.qtso.com/mdsdownload.html. While you are there, check out the download available for the new QI/QM report, which was due for implementation July 17, 2005. By the way, this is a great site that you might want to bookmark for future use.
       Clearly, changes keep happening at a startling pace, and we know of no one who has tons of spare time to research all these changes. Our advice is to use your computer to stay connected and up to date. When you find those great websites, bookmark them for return visits. You will be glad you did. Until next time, stay constant and keep changing.

If you have a question for Mabel, you can e-mail us at MabelMDS@aol.com.