Are you a “New Year’s resolution” kind of person? I am not, but I am a strong believer in establishing goals and setting intentions. Whether you prefer to make a resolution or set a goal, January 2023 is the perfect time to set yourself up for Minimum Data Set (MDS) 3.0 success.
The MDS changes that will be implemented come October 2023 are significant and should not be simply delegated to your amazing Resident Assessment Instrument (RAI) coordinator. Version 1.18.11 of the MDS will impact reimbursement systems, quality measurements, surveys and Five-Star, to name a few. As such, your policies, procedures, and mechanics around data capture also will need to be updated. This will be a major organizational shift in how you assess, document and report about care. It will impact your bottom line, your public data profile and — most importantly — the care you deliver to your residents.
The following timeline offers some guidance and practical suggestions to ensure a successful transition to the new MDS this year. A winning strategy begins now.
January – March
Now is the time to begin an interdisciplinary review of the updated MDS items. If you go to this page and scroll down to the “Downloads” section, then select the ZIP file labeled “MDS 3.0 Draft Item Sets v1.18.11”, you’ll find all you need to start this process. Within the ZIP file, you’ll find a PDF labeled “Item Set Change History” that summarizes all of the alterations to the MDS.
Identify what items were deleted, changed or added, and then circulate this information to the team to determine the following:
- What policies and procedures will need to be created/updated or retired?
- What documentation forms, either electronic or paper, will need to be created/adjusted or retired?
- Who’s going to do 1 and 2, and when will they do it by?
For example, under the category of “new items,” we are now hearing in the resident’s voice how they define their ethnicity, race and preferred language. We are assessing the lack of access to transportation and how that impacts daily living. Who is doing this assessment and how? How will this information make it into daily care and discharge planning?
New items (think QRP measures) from the Standardized Patient Assessment Data Elements (SPADEs) are included. Specifically, the two new process measures in SNF QRP: Transfer of Health Information to the Provider Post-Acute Care and Transfer of Health Information to the Patient Post-Acute Care are added into the mix. Absence of this MDS assessment data will have direct financial consequences.
April – June
Quarter two of 2023 will see the final version of the MDS 3.0 v1.18.11 item sets. Also, the RAI manual will be released. And as far as training, CMS hasn’t specified a time, but start looking for its announcements for MDS training.
With the final item sets and the manual, you are ready to finalize all policies, procedures and documentation forms that you identified in quarter one. A thorough review of the RAI Manual will reveal the specific details you’ll need to ensure proper implementation. In addition to the MDS items that have changed, consider items that haven’t changed but have historically challenged your facility. Take the opportunity to “reboot” and address these thorny items. Assessment of Section GG is a perfect example.
Some nursing homes have only completed Section GG for PPS assessments; now it is required for all OBRA assessments as well. As we’ve seen during MDS compliance audits, some facilities take information from their therapy notes to complete Section GG. This hasn’t been shown to be the best practice — plus, if the resident isn’t receiving therapy, there will be no therapy notes, so where will the data come from?
CMS has been remarkably silent about the many other systems, beyond resident assessment and care planning, that are impacted by the MDS changes. For example, how will the transition from the PHQ-9© to the PHQ-2 to 9© impact the depression end split? Items in Section O, Special Treatments, Procedures, and Programs, will be much more specific in type and in time/location of service delivery. This has care planning implications, but the added specificity will also provide details that suggest the possibility of PDPM adjustments.
Not just CMS, but many states also have not gone on record regarding Medicaid CMI reimbursement. How will they, and private insurers, respond to the elimination of required MDS items that generate a RUG? Might they require an Optional State Assessment? If so, how would that fit into your policies, procedures, and workflow?
Five-Star will be significantly impacted, and not only by the promised staffing study; the removal of Section G items means current staff acuity adjustments cannot be performed and several quality measures become incalculable. A Section G to GG would be reckless. CMS has yet to provide any guidance on this subject.
The proposed rule for FY 2024 hopefully will clarify many of these unanswered items, particularly the questions related to reimbursement.
July – September
OK, we are in the home stretch! I hope you took a vacation and feel refreshed! Practice makes perfect, and that’s what needs to happen in quarter three. Follow your soon-to-be-finalized MDS policies and procedures. In-service your team on the new documentation forms. Listen to their feedback. Are the requirements reasonable? Are your new policies and procedures setting you up for successful data capture?
Consider your existing QAPI projects. Do they need to be revised because of a reliance upon MDS data? Give the same consideration to your internal compliance programs, as they will likely need to be modified to be effective with the new data sets. Expand your compliance concerns to address the HIPAA-compliant method for sharing Provision of Current Reconciled Medication List to the Subsequent Provider and to the Resident at Discharge.
In addition to the information provided by CMS, consider other MDS education. When sourcing third-party education, make sure you know the teacher’s credentials. The American Association of Post-Acute Care Nursing offers various certification programs that have a clear ROI and are led by highly qualified master teachers.
You might make New Year’s resolutions or just be tenaciously goal-directed. You might also agree or disagree with the timeline I’ve put forth here. That’s fine. Whatever course you set, remember that success is the result of purposeful, focused activity.
One of the many things that I love about the nursing home industry is that there is no challenge we haven’t mastered. We will succeed, and resident care will improve as a result.
May 2023 take you from strength to strength, for you and our nation’s elders.
Steven Littlehale is a gerontological clinical nurse specialist and chief innovation officer at Zimmet Healthcare Services Group.
The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.
