- McKnight's Long-Term Care News https://www.mcknights.com/blogs/mds-intelligence/ Wed, 20 Dec 2023 19:26:38 +0000 en-US hourly 1 https://wordpress.org/?v=6.1.4 https://www.mcknights.com/wp-content/uploads/sites/5/2021/10/McKnights_Favicon.svg - McKnight's Long-Term Care News https://www.mcknights.com/blogs/mds-intelligence/ 32 32 “No man is a failure who has friends” — an MDS Merry Christmas https://www.mcknights.com/blogs/mds-intelligence/no-man-is-a-failure-who-has-friends-an-mds-merry-christmas/ Wed, 20 Dec 2023 19:26:29 +0000 https://www.mcknights.com/?p=142950 As Christmas and the new year approach, I get nostalgic. I like to think back on good old childhood memories. For me those are the 1970s and ’80s.

 I remember one Christmas, I was probably 7 years old, I wanted a child’s toolbox full of working tools like a kid-sized hand saw, screwdriver, wrench and a hammer. They all came in a metal toolbox that had a latch and a handle so you could carry it around.

I must have seen it in a store and asked for it, like Ralphie did with his Red Ryder BB gun. Lo and behold, on Christmas morning, there it was. I can still feel the elation of that moment. I also remember that in short order I was in the garage sawing up old cardboard boxes and making stuff that I proudly showed my parents. 

I hope you have memories like that. Just a few months before my mom passed away a few years ago, we all got out the photo albums and 8 mm films and reminisced about those days. It was a precious time I’ll never forget. Remember Clark Griswold in the attic

2023 has been a difficult year. The regulatory onslaught was brutal. But we are surviving. These challenges have also made me nostalgic. I often think about the day I made what I thought would be a temporary switch from acute care to long-term care. I became an MDS coordinator. A competent ICU step down nurse, I quickly realized I was out of my element in this new role.

In 2001, the MDS nurse was something new. PPS had just been initiated a few years earlier and the industry was still reeling. The MDS became electronic with that change and was required to be submitted to the state, via a modem. Do you remember the sound those things made? 

Quality Indicators, now quality measures, were new as well. No one really knew what was going on. Someone had to oversee it all. And so, the MDS coordinator position was born. 

Today there are a litany of resources available for the MDS nurse to rely on for advice and support. It is a wonderful thing to watch online communities take root and grow into vibrant discussions. Organizations like the American Association of Post-Acute Care Nursing (AAPACN), and others, have become the gold standard for educational opportunities and certifications. 

In those days, however, unless you knew someone who was also an MDS coordinator, there were relatively few resources available to answer questions and offer guidance. My paperback MDS manual was only a few hundred pages long and was scant on coding tips and clarifications. But those were the good old, “less complicated” days, remember? 

I also remember through the years those who helped me grow, many of whom have become career long friends. I remember my first administrator who had confidence that I could do the job. 

I remember several others I respected who came along, offered guidance, helped me gain confidence, and shed light on previously unrealized abilities. My initial nursing career plans did not include long-term care and these incredible people are the reasons I now do what I do. 

I came to understand through their compassion and care for this patient population, that the MDS and all it represents, is a powerful tool for good, that when a community of caregivers surround it and it is properly utilized, our residents are the beneficiary. What a joy!

As I think back, I am grateful for Randy Lewis, Joy Powers, Sandy Deakins, Mary Marshall, Diane Brown, Mendee Rock, Linda Estes, Manning McGraw, Sumit Malhotra and the many others who carried me along like a leaf on the river of this unexpected career.

Thank you also to McKnight’s Kimberly Marselas for reminding us of what it was like to have good friends by sharing this year’s Amazon ad, “Joy is shared,” in a recent article. I have a lump in my throat every time I watch it.

The RAI process is a wonderfully formidable task that cannot be accomplished alone. I hope that you have a circle of friends who help you grow and care about the MDS tasks you accomplish each day. Their support is indispensable. The outcome of those relationships will produce remarkable results, especially for the residents you care for.

Gracing our residents with those outcomes is the reason most of us do what we do in long term care.  Clarence the angel said it best to George Bailey in “It’s a Wonderful Life”: “No man is a failure who has friends.” 

I feel that intensely as I reminisce. How about you? 

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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The MDS on Christmas vacation: ‘It’s a beaut Clark, it’s a beaut!’ https://www.mcknights.com/blogs/mds-intelligence/the-mds-on-christmas-vacation-its-a-beaut-clark-its-a-beaut/ Tue, 28 Nov 2023 17:00:00 +0000 https://www.mcknights.com/?p=142127 I love this time of year. Christmas is on its way. I especially love the holiday movie classics, “A Christmas Story,” “Planes, Trains and Automobiles,” “Miracle on 34th Street,” “White Christmas,” “It’s a Wonderful Life,” and, of course, “Christmas Vacation.” We watch them all every year, with vigor. 

“National Lampoon’s Christmas Vacation” has so many funny one-liners. Remember when Clark finally gets the house lit up and each family member comments on the spectacle? When it finally gets around to Clark’s father, he is at a loss for words and all he can get out is, “It’s a beaut Clark, it’s a beaut!” Just then, Cousin Eddie shows up, and, well, you know the rest.

It’s been kind of like that this year, hasn’t it? We finally got the new MDS in all its glory and then things started to go downhill — kind of like Cousin Eddie showing up. The challenges we’ve faced with this implementation have been unprecedented and many. 

All of the prep work and long training hours hit a snag when we all began to realize that there were, and still are, issues to get used to and some that still need to be talked about. I’m thinking specifically about the unfolding changes to the quality measures and Five-Star rating now that section G has been officially retired. 

There are five quality measures that will be affected by these changes. The table below crosswalks these five measures to their GG equivalent measures. Note that measures one through four affect the Five-Star rating. 

Recently, the Centers for Medicare & Medicaid Services released QSO-23-21-NH in which it spelled out the effect that removal of section G would have on the four quality measures that will impact the Five-Star rating. 

Specifically, CMS indicated that, “Starting in April 2024, CMS will freeze (hold constant) these four measures on Nursing Home Care Compare. In October 2024, CMS will replace the short-stay functionality QM with the new cross-setting functionality QM, which is used in the SNF Quality Reporting Program (QRP). The remaining three measures will continue to be frozen until January 2025 while the data for the equivalent measures are collected.”

CMS also posted an announcement in November addressing two important impacts that this Section G to GG transition will have on the reporting of all five quality measures on the IQIES MDS 3.0 Facility-Level Quality Measure (QM) Report. 

  • “… these five measures were frozen (held constant) in the iQIES MDS 3.0 Facility-Level and Resident-Level QM Reports on 10/1/2023. Starting on the first Monday of November, iQIES will process any qualifying records submitted on or after 10/1/2023 that had a target date prior to 10/1/2023 in order to provide updated measure data based on newer submissions. 
  • “… MDS records with a target date on or after 10/1/2023 will not be included in these impacted measures. As a result, if the requested report period (i.e., Begin Date Range and End Date Range) in the MDS 3.0 QM Reports includes dates on or after 10/1/2023, then there would be expected decreases in the numerator and denominator due to the MDS G-GG transition.”

In addition to these notifications, CMS also released MDS 3.0 Quality Measures USER’S MANUAL (v16.0) which contains the technical specification changes to the quality measures noted above. Providers should become familiar with the revised specifications. All five measures contain striking differences that we will need to understand and get used to. 

One example of this is the current measure, “Percent of Residents Whose Ability to Move Independently Worsened,” which measured the change over time of MDS item G0110E Locomotion on unit. This MDS item was defined as, “How a resident moves between locations in his/her room and adjacent corridor on same floor. If in wheelchair, self-sufficiency once in chair.” 

The GG Equivalent Measure, “Percent of Residents Whose Ability to Walk Independently Worsened,” measures only MDS item GG0170I Walk 10 feet defined as, “Once standing, the ability to walk at least 10 feet in a room, or similar space.”  The GG equivalent measure eliminates measuring a large portion of the long-term care community who use wheelchairs for locomotion. This is not an equivalent measure and begs the question, “Is this really a useful measure for the long-term care population?” 

Another example is the current measure, “Percent of Residents Whose Need for Help with Activities of Daily Living Has Increased.” This measure used the four late loss ADLs, Bed Mobility, Transfer, Eating and Toilet Use as proxies for declines in function over time. 

While the measure title and description has not changed for the GG equivalent measure, the MDS items it measures, again, are significantly different from what the section G items measured in the current measure. The revised QM measures the following items out of section GG, Sit to Lying, Sit to Stand, Eating, and Toilet Transfer.

You are probably as surprised as I was when I first saw this new measure. Take toilet use vs. toilet transfer for example. In section G, toilet use was defined, “…as how resident uses the toilet room, commode, bedpan, or urinal; transfers on/off toilet; cleanses self after elimination; changes pad; manages ostomy or catheter; and adjusts clothes. Do not include emptying of bedpan, urinal, bedside commode, catheter bag or ostomy bag.”

The GG equivalent toilet transfer only represents the resident’s, “…ability to get on and off a toilet of commode.” This too is not an equivalent measure and again begs the question, “Is this really a useful measure for the long-term care population?” 

These are huge changes. Keep in mind that all, but the discharge function score measure, are long-stay measures. It is relevant to remember that Section GG was developed as a standardized way to measure functional ability across post-acute care, not long-term care. It seems as if CMS is trying to pound square pegs into round holes here and it’s a bit bewildering as to why, the IMPACT Act notwithstanding. Nonetheless, preparation will be key as these new measures are phased in over the next year.

When Cousin Eddie showed up at the Griswolds to a surprised and befuddled Clark, Eddie askes “Clark, are you surprised?” To which Clark responds, “Surprised, Eddie … if I woke up tomorrow with my head sewn to the carpet, I wouldn’t be more surprised than I am right now.”

These G to GG equivalent measures are no less surprising and puzzling. Perhaps if CMS had engaged the provider community to some degree before they finalized these changes, we may not be having this conversation. But here we are. The innocence of the MDS is that it started out as a standardized way to assess residents, create care plans, and measure quality. The fundamental idea is a “beaut” — it’s the nursing process for goodness’ sake. 

These new complexities, in my opinion, take away some of the original intent. It doesn’t have to be this hard. Like the arrival of Cousin Eddie, we will have to accommodate these measures. Part of that may mean we will need to press CMS to make continued adjustments to these long stay measures affected by the G to GG transition so that they better reflect the long-term population in our communities. I hope there may be opportunities here. 

In the end, despite Cousin Eddie’s unanticipated appearance and Clark’s Christmas bonus debacle, the Griswolds were able to give Christmas to Eddie’s kids. Christmas really does embody the idea of hope. 

Amid all the changes we have had to assimilate this year, let’s encourage each other not to lose sight of the gifts we bring each day to the residents we serve. A little hope goes a long way. 

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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Section D surprises! The season’s biggest change https://www.mcknights.com/blogs/guest-columns/are-these-mds-changes-a-trick-or-a-treat/ Tue, 31 Oct 2023 18:39:44 +0000 https://www.mcknights.com/?p=141309 There has been a slogan that has circulated on social media recently that goes like this: “Fall is proof that change is beautiful.”

Hmm… I suppose individual perspective is the key to whether that is true.

I remember one time when I was a much younger inexperienced man, I mistakenly left my car in neutral on a slight hill after changing the oil. 

I went into the house to retrieve a grocery list and discovered, after hearing a loud bang, that my car had rolled down the hill into my neighbor’s barn. 

The changes that I faced then weren’t so beautiful. Thankfully no one was hurt, but my wallet and my pride suffered some serious loss. Lesson learned.

This fall has brought a cornucopia of changes to nursing homes. I’m sure you feel the weight.  Not all of them have been what we expected. The quality measure changes, for example, contain some surprising crossover from section G to GG “equivalent.”

Four weeks post implementation, the Centers for Medicare & Medicaid Services continues to make significant revisions to the MDS coding guidelines as well with the release of the sixth versions of the data set, an item set supplemental document and two errata documents. CMS had three-plus years to get this right. What happened that so many revisions are having to be made?

Whatever the reason, the most significant revision occurred with the release of these errata documents, in particular the coding guideline revisions to the depression interview, now the PHQ-2 to 9. 

Added

p. D-2: D0100 serves as a gateway item for the Resident Mood Interview (PHQ-2 to 9©) and D0500, Staff Assessment of Resident Mood (PHQ-9-OV©). The assessor will complete the Staff Assessment only when D0100 is coded 0, No. The assessor does not complete the Staff Assessment based on resident performance during the Resident Mood Interview.

p. D-3: Resident refusal or unwillingness to participate in the interview would result in Item D0100 being coded 1, Yes, and code 9, No response being entered in Column 1. Symptom Presence. Assessors should proceed to Item D0700, Social Isolation in the case of resident refusal or unwillingness to participate.

p. D-5: If both D0150A1 and D0150B1 are coded 9, leave D0150A2 and D0150B2 blank, then end the PHQ-2©, leave D0160, Total Severity Score blank, and skip to D0700, Social Isolation.

p. D-6: If both D0150A1 and D0150B1 are coded 9, leave D0150A2 and D0150B2 blank, then end the PHQ-2©, leave D0160, Total Severity Score blank, and skip to D0700, Social Isolation.

p. D-11: If only the PHQ-2© is completed because both D0150A1 and D0150B1 are coded 9, leave D0150A2 and D0150B2 blank, then end the PHQ-2©, leave D0160, Total Severity Score blank, and skip to D0700, Social Isolation.

p. D-11: If symptom frequency in items D0150A2 through D0150I2 is blank for 3 or more items, the interview is deemed NOT complete. Total Severity Score should be coded as “99,” do not complete the Staff Assessment of Mood, and skip to D0700, Social Isolation.

p. D-13: When staff determine the resident is not interviewable (i.e., D0100 = 0, No), scripted interviews with staff who know the resident well should provide critical information for understanding mood and making care planning decisions.

p. D-13: 1. Interview staff from all shifts who know the resident best. Conduct the staff interview in a location that protects resident privacy.

p. 6-37: Evaluate for depression. Signs and symptoms of depression are used as a third-level split for the Special Care High category. Residents with signs and symptoms of depression are identified by the Patient Mood Interview (PHQ-2 to 9©) or the Staff Assessment of Patient Mood (PHQ-9-OV©). Instructions for completing the PHQ-2 to 9© are in Chapter 3, Section D. Item D0100 is a gateway question to determine when the Patient Mood Interview (D0100 is coded 1, Yes) or the Staff Assessment of Patient Mood is to be conducted (D0100 is coded 0, No). Refer to Appendix E for cases in which the PHQ-2 to 9© or PHQ-9-OV© is complete but all questions are not answered. For the PHQ-2 to 9©, if either D0150A2 or D0150B2 is coded 2 or 3, continue asking the questions below, otherwise end the PHQ interview. Assessors should proceed to D0700, Social Isolation in the case of resident refusal or unwillingness to participate. The following items comprise the PHQ-2 to 9© and PHQ-9-OV© for the Patient and Staff assessments, respectively:

Removed

p. D-13: PHQ-2 to 9© Resident Mood Interview is preferred as it improves the detection of a possible mood disorder. However, a small percentage of residents are unable or unwilling to complete the PHQ-2 to 9© Resident Mood Interview. Therefore, staff should complete the PHQ-9© Observational Version (PHQ-9-OV©) Staff Assessment of Mood in these instances so that any behaviors, signs, or symptoms of mood distress are identified.

p. D-13: Even if a resident was unable to complete the Resident Mood Interview, important insights may be gained from the responses that were obtained during the interview, as well as observations of the resident’s behaviors and affect during the interview.

Considerations

These guidelines are pretty straight forward. CMS has now unequivocally indicated that the PHQ-9 OV is only to be conducted in cases where B0700 (Makes self-understood) is coded 3, rarely or never understood. 

Until these revisions, the RAI manual guidance allowed the staff interview for depression to be conducted when a resident was unable or unwilling to complete the PHQ-9, and more recently the PHQ-2 to 9©, Resident Mood Interview.

It wasn’t until this year, FY 2024, after the PHQ data was labeled a SPADE, or Standardized Patient Assessment Data Element, that the guidance changes occurred, and not until well after the final RAI Manual was posted. Why now?

It is interesting to note that the OASIS, LCDS and IRF-PAI all contain the PHQ-2 to 9 but no staff assessment for depression. Ostensibly this is why these revisions have occurred, to make the reporting of depression data among post-acute providers as standardized as possible. 

The fact remains, however, that CMS has noticed that the incidents of depression indicators have been an outlier under PDPM compared to the RUG 66 grouper. That means money. Parity happened for a reason. It is difficult not to think that limiting the times that the depression end split is in play was a subtext impetus for these revisions.

I am perplexed, though, as to why only the PHQ-2 to 9 has been singled out.

I find it interesting that the BIMs has not undergone the same scrutiny. Considered a SPADE as well, the BIMS also has a staff assessment component that continues to be allowed to be utilized in specific situations where the BIMs is stopped, and when there is an unanticipated discharge for a Part A resident. 

While the BIMs is also a standardized assessment embedded in the OASIS, LCDS and IRF-PAI, there is no standardized staff assessment for cognitive status in these tools either. Could it be that since cognitive performance, being only one fifth of SLP considerations under PDPM, doesn’t rise to the level of the PHQ in its financial impact on the rate?

In the end, the CAA and care plan requirements remain for residents with depressive symptoms, even if they are unable or unwilling to communicate them. Page D-13 of the RAI Manual continues to indicate, “Alternate means of assessing mood must be used for residents who cannot communicate or refuse or are unable to participate in the PHQ-2 to 9© Resident Mood Interview. This ensures that information about their mood is not overlooked.” 

Until this revision, that alternate means was PHQ-9 OV. Now, providers are left wondering what CMS means by “alternate means.” At least one thing is clear, if these residents are identified by whatever, “alternate means” is used to identify depression symptoms, the added acuity that these residents represent will not be reflected in the PDPM rate.  

Thank goodness the leaves have finally changed and, for goodness sakes, let’s hope that the leaves of the RAI manual have finally fallen into place so we can get busy with the task of implementation without hesitating for the next errata. It’s hard to be thankful for these late surprises.

Autumn is beautiful here in eastern Tennessee. The colorful foliage and cooler weather are certainly a wonder. I like sitting out by the fire pit, seeing my breath in the air, smelling the first hearth fire smoke, listening to the geese fly noisily overhead, watching the squirrels collect their winter stores, and anticipating the holidays. I am thankful for this change.

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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Trick or treat? MDS changes are in the bag https://www.mcknights.com/blogs/mds-intelligence/trick-or-treat-mds-changes-are-in-the-bag/ Tue, 03 Oct 2023 16:00:00 +0000 https://www.mcknights.com/?p=140317 When I was a kid, I loved getting dressed up for Halloween. I remember especially a clown (funny not scary) costume I got one year. I couldn’t wait to put it on and be transformed into another world. The candy was a bonus.

My absolute enjoyment of changing into a different character each year for a few hours was probably a harbinger of things to come later in life.  Although professionally I am a nurse specializing in post-acute care regulatory affairs and education, on the side I am an amateur thespian.

You can routinely find me on the streets of Jonesborough, TN, dressed as an early 20th century baseball player leading a town tour, on stage at the Jonesborough Repertory Theater, or bringing a long passed on Jonesborough citizen to life in our annual cemetery play, “A Spot on the Hill.”

If you have been paying attention, you recognize that what the MDS has changed into this go round is significant. Item sets and RAI Manual revisions, now staffing calculations and quality measures specifications, have taken front and center. No clowning around here. However, the reason for this change is something to which we should also pay attention.

You are probably aware that the changes we are now acclimating to are the result of a piece of legislation that was signed into law back in 2014 called the Improving Medicare Post Acute Care Transformation Act, or IMPACT act.

In a nutshell, this legislation requires the reporting of standardized, interoperable patient assessment data with regard to quality measures and standardized patient assessment data elements (SPADEs), to allow for the exchange of data among post-acute and other providers, in order to improve Medicare beneficiary outcomes through shared decision making, care coordination and enhanced discharge planning. That’s a descriptive mouthful. 

Unlike a mouthful of Halloween candy though, this delicious description is important to our understanding of the revised MDS data that we are now collecting. The SNF Quality Reporting Program (SNF QRP) relies on this standardized data to fulfill its responsibility to the IMPACT act. In other words, the SNF QRP creates the quality reporting requirement to which we owe MDS 3.0 v1.18.11. 

Annually, the Centers for Medicare & Medicaid Services posts documents that indicate which items on the MDS contribute to this reporting requirement.  With the implementation of v1.18.11 of MDS 3.0, the number of these data elements increased from 99 pre MDS 3.0 v1.18.11, to 230 in the revised data set. That’s 131 more MDS data elements that are required to be reported because of the SNF QRP. 

Also, the FY 2024 SNF PPS final rule finalized a new reporting standard. Starting with MDS data collected in CY 2024, facilities will be required to submit 100% of the QRP required data on 90% of the MDS assessments submitted to IQIES. 

This requirement carries with it some potentially hefty financial implications for SNFs that are non-compliant to the tune of a 2% reduction to the annual payment update or APU (adjusted market basket update). For FY 2024, that would mean a 6.4% update would be reduced to 4.4% that would then be further adversely affected by a 2.3% parity adjustment. Combined with Skilled Nursing Facility Value Based Purchasing (SNF VBP), sequestration and wage index adjustments, that’s not small potatoes. 

And while the SNF QRP is the primary impetus for the MDS changes this year, some of the standardized data will also impact CMS’ other quality reporting efforts like the SNF VBP and Five-Star Quality Rating System. The SNF VBP shares the following measures with the SNF QRP: discharge function Score, healthcare associated infections that require hospitalization, falls with major injury, and discharge to community. The revised Five-Star rating will share the following: skin integrity post-acute pressure ulcer injury measure, discharge function score, and discharge to community. 

One time my brother and I foolishly decided that we would pull a Halloween prank on a friend by soaping the windows on his car late at night. “Boy,” we thought, “will he be surprised.” We wore Halloween masks, just in case. A bit older at this point, I was now the werewolf. 

As we were completing our mischief in the apartment complex parking lot, we noticed a young woman, apparently another tenant, walking toward us and realized that she was writing down our license plate number. Not to be discovered by our friend, we thought it would be helpful to explain to her what we were doing and that this was a friend’s car. 

Forgetting our Halloween attire, as we ran after her to try to explain, we watched in dismay as she quickly disappeared into her apartment. Suddenly realizing that law enforcement may be our next surprise, we left in haste. A humorous, but real, lesson learned.

And so, here we are. It’s October 2023. All the hype is now reality.  As we grapple with successful implementation of the revised MDS over the next several months, let’s be sure that we aren’t soaping any windows. 

From the SNF QRP perspective, a single misplaced dash is all it will take to wake up in FY 2025 with an APU that is 2% less than everyone else’s. Nothing funny about that lesson.  

The changes to the MDS are in the bag. It’s time for trick-or-treat. Are you prepared?

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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CATs in the cradle, CAA changes coming soon https://www.mcknights.com/blogs/mds-intelligence/cats-in-the-cradle-caa-changes-coming-soon/ Tue, 05 Sep 2023 19:35:46 +0000 https://www.mcknights.com/?p=139280 Have you listened to the song, “Cats in the Cradle” by Harry Chapin? It’s a folk song written in the early 1970s. If you haven’t heard it, give it a listen. I think you’ll like it.

The phrase “Cat’s in the cradle” is often used to refer to situations in which one person has neglected another, or there is a total breakdown of communication. It’s the theme of this song.

I have been keenly aware of the risk of leaving the cat in the cradle as I have been preparing and providing training related to MDS 3.0 v1.18.11 — there is so much new to get used to. I’ve often expressed that this feels more like MDS 4.0. 

The final version of the RAI Manual was released by the Centers for Medicare & Medicaid Services just a few weeks ago. One area with significant revisions that seems to have been somewhat overlooked in all the hubbub is Chapter 4 and Appendix C of the RAI Manual. 

Have you taken a close look at the changes? Your interdisciplinary team should, before Oct. 1. Here are a few of the key revisions:

CATs

The following CAT Specifications include changes. 

  • CATs for CAA 5: ADL Functional/Rehabilitation Potential
  • CATs for CAA 6: Urinary Incontinence and Indwelling Catheter
  • CATs for 16: Pressure Ulcer/Injury
  • CATs for CAA 11: Falls

CATs for CAAs 5, 6 and 16 were revised to remove references to section G and add section GG 0130 and GG0170 items. The section G balance items were removed from the CATs for CAA 11. However, references to balance remain in CAA 5.

  • CATs for CAA 20: The triggering condition changed, not only from the current trigger, but from the DRAFT Manual. Now the trigger is, “Resident wants to or may want to talk to someone about returning to community as indicated by: Q0500B = 1 or 9”.

CAAs

There have been many revisions to the CAA Resources. Here are some prominent ones that will require IDT attention.

  • Section GG0130 and GG0170 have replaced section G items throughout the CAA resources. Special attention needs to be paid to the breadth of section GG evaluation vs section G.
  • Reference to the PHQ 2-9 now populates specific CAA resources. It will be important to consider the resident responses to MDS items D0150A and D0150B regardless of whether the remaining seven questions are considered.
  • Three distinctly new line items have been added, one to CAA1 Delirium (Terminal condition (J1400) and two to CAA 19 Pain (Venous or arterial ulcers (M1030) and Limits participation in rehabilitation therapy (J0520)). These will require the IDT to analyze concepts they have not encountered before in these CAAs.
  • In multiple CAAs, Item J1900, falls with major injury, has been added as an expanded approach to further analyzing the impact of falls.
  • Item J1400, Terminal Condition has been added to several CAAs as well to further consider the impact that end of life/hospice services has on the resident’ care plan needs.
  • While the term “social isolation” is peppered throughout the current CAA resources, with the implementation of v1.18.11, new MDS item D0700, Social Isolation, now shows up specifically in CAA7, Psychosocial wellbeing as it relates to loneliness. Considering this as a social determinant of health within the CAA resources will be a new concept for IDTs that will need to assimilate it into care planning.
  • Now that section K0520 and section O0110 items have additional columns and time frames to consider, teams will need to recognize how these additions potentially change their CAA analysis.
  • The pain interview has expanded into three specific instances when pain might interrupt things like sleep, therapy and day-to-day activities. This expansion has been added to several CAA resources and teams will need to consider the implications in analysis and care planning.

While this is not an exhaustive list, it is fodder for considering that while the number of CAAs has not grown, the new and revised MDS items have expanded the IDT’s responsibility to integrate these changes into the RAI process.

There should be a sense of urgency to get this right. The data that will be produced by a completed MDS 3.0 v1.18.11 will be different in many significant ways than an MDS completed prior to Oct. 1 with residual impact to care plan details. 

Adapting to these changes is no small task and will require attention to detail, not to mention staying alert to the fact that on the SNF/LTC Open Door Forum CMS admitted that there are two CATs (6 and 16) in error, and that a forthcoming errata document or some other type of correction is in the works. More to learn.

The chorus to “Cat’s in the Cradle” goes like this:

And the cat’s in the cradle and the silver spoon,

Little boy blue and the man in the moon.

“When you coming home, Dad?” “I don’t know when,”

But we’ll get together then

You know we’ll have a good time then.

This song makes me nostalgic, partly because it was written during the time of my childhood and hearing that style takes me back to fond memories. However, more powerfully, it reminds me of my own dad and how important time is now. He will be 90 this year.

I called him up just the other day. I wanted to hear his voice, see what he had to say. I plan to spend time with him later this fall. I wish it were today. 

Now is the time to get together around the new CATs and CAAs — not then. Don’t neglect these important changes. Begin now to talk about them and how your IDT will work them into your RAI process before Oct. 1.

Waiting could cause a total breakdown of communication. You won’t have a good time then.

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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New interviews in the MDS? We’ve been scripted! https://www.mcknights.com/blogs/mds-intelligence/new-interviews-in-the-mds-weve-been-scripted/ Tue, 08 Aug 2023 16:00:00 +0000 https://www.mcknights.com/?p=138268 Have you ever watched or listened to an interview where the person being interviewed consistently dodges the questions and responds with something completely unrelated or that doesn’t really answer the question? It drives me crazy!

As we enter another presidential election cycle the airwaves have been and will be filled with these types of scenarios, the main reason I avoid the primary “debates.” They aren’t debates. 

These debacles are mostly sound bites and vitriol. Frequently, answers given bear little resemblance to the questions and I am left, as we say it here in the South, “bumfuzzled.” I’m frustrated by the penchant for a lack of integrity, honesty and truthfulness when it comes to this kind of public discourse. I’ll step down from my soapbox now.

The resident interviews in the MDS, however, should not take on this flavor. Getting the residents’ honest voice in their responses is the clear goal throughout the RAI Manual and conditions of participation. 

We are all familiar with the scripted interviews in sections C, D, F and J. The entire MDS should be viewed as one long interview, in my opinion. The RAI Manual Appendix D, “Interviewing to Increase Resident Voice in MDS Assessments,” and Appendix PP of the SOM are helpful in this regard.

However, as we gear up for implementation of MDS 3.0 v1.18.11 on October 1, it occurs to me that there is a new set of interviews coming our way. Consider the items that have been added for the SPADE category, “Social Determinants of Health (SDOH).” 

Formally, the Centers for Medicare & Medicaid Services does not call them that, but just read the text of the draft RAI Manual and you will discover that that is exactly what they are. I hope you’ve noticed this as you have been preparing. Here is a sampling of the RAI instruction.

Ethnicity and Race

Ask the resident to select the category or categories that most closely correspond to their ethnicity and race from the lists provided in A1005 and A1010

A1005: Are you of Hispanic, Latino/a, or Spanish origin?

A1010: What is your race?

If the resident declines to respond, do not code based on other resources (family, significant other, or guardian/legally authorized representative or medical records).

Language

Ask for the resident’s preferred language.

Ask the resident if they need or want an interpreter to communicate with a doctor or health care staff.

A1110A: What is your preferred language?

A1110B: Do you need or want an interpreter to communicate with a doctor or health care staff?

Only if the resident — even with the assistance of an interpreter — is unable to respond, a family member, significant other, and/or guardian/legally authorized representative should be asked.

Transportation

Ask the resident:

A1250A: “In the past six months to a year, has lack of transportation kept you from medical appointments or from getting your medications?”

A1250B: “In the past six months to a year, has lack of transportation kept you from non-medical meetings, appointments, work, or from getting things that you need?”

If the resident declines to respond, do not code based on other resources (family, significant other, or legally authorized representative or medical records).

Health Literacy

This item is intended to be a resident self-report item. No other source should be used to identify the response.

Ask the resident:

B1300: “How often do you need to have someone help you when you read instructions, pamphlets, or other written material from your doctor or pharmacy?”

Social Isolation

This item is intended to be a resident self-report item. No other source should be used to identify the response.

Ask the resident: 

D0700: “How often do you feel lonely or isolated from those around you?”

Did you notice? Every one of these new items begins with the instruction, “Ask the resident.” These items are intended to be self-reported, just as much as the scripted interviews we have grown accustomed to are. 

Social determinants of health items have been added to the RAI because, according to the Agency for Healthcare Research and Quality, 30% to 55% of health outcomes (are) attributed to SDOH. That’s something worth paying attention to and getting the residents’ voice on these issues is key. 

With the revised MDS, the SDOH items are only required for reporting purposes, mandated by the IMPACT Act. However, as I see it, there are at least two major implications to getting this right.

First, CMS has finalized a health equity adjustment in the SNF Value Based Purchasing (VBP) program that rewards SNFs for having a larger mix of dual eligible residents (Medicare and Medicaid). The CDC has indicated that, “Achieving health equity requires addressing social determinants of health and health disparities.” 

This year, as we face an expanded VBP, it will be crucial that our engagement of underserved populations, like dual eligibles, has the intended effect of mitigating health disparities and inequities by identifying and addressing known social determinants of health.

Second, the PDPM continues to be a fruitful reimbursement methodology regarding its ability to help us identify unique resident characteristics within the payment structure that leads us to better patient care. One of the ways that this can be achieved is by understanding what is considered a skilled level of care from CMS 100-2 Chapter 8

Consider CMS’ Health equity initiative Priority 4: Advance Language Access, Health Literacy and the Provision of Culturally Tailored Services. Notice that within one of the core tenants of this initiative, CMS has identified two important concepts that we will be recording on the MDS starting in October, health literacy and language access.

How’s that for a gimme? Not only will there be a positive $ adjustment possibility to your VBP scores as you engage underserved populations, within that population there are multiple opportunities to identify SDOH and get paid for it. 

In CMS 100-2 Chapter 8, one specific example of a skilled nursing service is, “Teaching and Training Activities.” Guess what? Two items that we will be coding directly on the revised MDS are B1300 health literacy and A1110 language. 

With the addition of SDOH items we will be free to engage underserved populations (VBP adjustment) with teaching and training activities (QRP SDOH). Both can lead to positive financial outcomes which, in the end, should lead to better patient care and outcomes.

I am encouraged that as we begin to assimilate to the revised MDS and the newness of concepts like health equity and social determinants of health, we will grow in our understanding of their value to the care we provide. As such, accuracy, truthfulness, and honesty should guide our way as we begin the task of engaging with the “new” interviews. 

We will have been scripted. Let that guide your way. I’d like to stay off my soap box for a while.

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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It’s Independence Day y’all! https://www.mcknights.com/blogs/mds-intelligence/its-independence-day-yall/ Tue, 11 Jul 2023 16:00:00 +0000 https://www.mcknights.com/?p=136945 I love summer and especially the July 4th holiday. In the small town where I live, we have an event called “Jonesborough Days.” It’s a two-day celebration with a parade, food vendors, music, fireworks and my favorite, the free watermelon.

The weather is usually hot in July here in East Tennessee, and there is nothing like biting into an ice-cold slice of perfectly ripe watermelon, letting the juice run down your chin, spitting out the seeds and looking for some water to wash off those deliciously sticky fingers.

This July is also the time for us to be preparing for the changes to the MDS that will be effective on October 1. There is so much for us to consider as we approach this historic adjustment.

One principle that undergirds all these changes and should be the foundation of everything we do for our residents, is that the care we provide ensures that each resident receives the appropriate treatment and services to, “attain or maintain his or her highest practicable physical, mental and psychosocial well-being.”

Mentioned no less than 72 times in the State Operations Manual Appendix PP, highest practicable physical, mental and psychosocial well-being is defined as “…the highest possible level of functioning and well-being, limited by the individual’s recognized pathology and normal aging process.”

Furthermore, “highest practicable” is determined through the comprehensive resident assessment and by recognizing and competently and thoroughly addressing the physical, mental or psychosocial needs of the individual.”

Maybe I’ve just been in the holiday spirit, but I can’t help but hear, “Let freedom ring!”

With MDS 3.0 v1.18.11, it seems to me that we have a significant opportunity to consider more fully the idea of “highest practicable physical, mental and psychosocial well-being,” especially since section GG will be the final say, across the PAC spectrum, with regard to resident functional ability and goals. 

In the FY 2024 rule-making cycle so far, CMS has proposed the adoption of the Discharge Function Score (DC Function) measure beginning with the FY 2025 SNF QRP. 

The SNF Discharge Function Score Measure determines how successful each SNF is at achieving an expected level of functional ability for its residents at discharge. The final Discharge Function Score for a given SNF is the proportion of that SNF’s stays where a resident’s observed discharge score meets or exceeds their expected discharge score.

This new measure would replace the topped-out SNF QRP Application of Functional Assessment/Care Plan measure. 

Also, if the proposed changes to the SNF QRP are finalized, CMS plans to dispense with two more SNF QRP functional outcome measures, the Change in Self-Care and Mobility Scores for Medical Rehabilitation Patients.

That will leave only three SNF QRP measures addressing discharge outcomes based on standardized self-care and mobility items in section GG. 

The proposed discharge function score measure, in particular, is intended to “…show that SNFs with low scores are not producing the functional gains that they could be for a larger share of their residents and would provide actionable feedback to SNFs that has the potential to hold providers accountable and encourage them to improve the quality of care they deliver.”

It seems to me that this is an opportunity to step out of the weed bed that having to consider quality measures driven by sections G and GG has created and focus clearly on how well we are doing in helping our residents attain their highest practicable physical, mental, and psychosocial well-being from one standard set of metrics. 

Maybe it’s just the lingering holiday spirit again, but I can’t help but hear “independence.”

We have the responsibility, the privilege and the joy of helping those we care for to achieve higher levels of physical freedom and independence. Now there is a standardized QRP measure to gauge how well we are doing.

Many of the other new items on MDS 3.0 v1.18.11, like those that identify social determinants of health, will press us into understanding how we can accomplish this in other aspects of our resident’s care needs as well. 

I am patriotic. I grew up in an era where being thankful for our freedoms was a way of life.  

Remember the poem on the base of the Statue of Liberty? “Give me your tired, your poor, Your huddled masses yearning to breathe free, The wretched refuse of your teeming shore. Send these, the homeless, tempest-tossed to me, I lift my lamp beside the golden door!”

Perhaps in that poem can be found some of the hope we impart to those who enter the doors of our SNFs like freedom, liberty, independence. In other words, the highest practicable physical, mental and psychosocial well-being.

This year, I celebrated the 4th of July as I always do, like the big kid that I am. I watched the parade, ate festival food and watermelon, listened to great music, and was out under the night sky to watch the fireworks. 

I’m physically able to do those things, and I’m grateful. And I’m glad that I can play a small part in helping those who can’t regain some ability to do the things they might enjoy doing again. 

It’s Independence Day y’all.    

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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The movie is never as good as the book… usually https://www.mcknights.com/blogs/mds-intelligence/the-movie-is-never-as-good-as-the-book-usually/ Tue, 13 Jun 2023 21:30:52 +0000 https://www.mcknights.com/?p=136030 Have you ever read a really good book that was subsequently made into a movie? I have. Time after time, after watching the movie, I end up walking away thinking, “I wish I had just stuck with the book… again.” 

As we face MDS 3.0 v1.18.11 implementation this October, there have been a slew of resources made available to SNFs to begin preparations for this change. They are worth taking advantage of. As I have said many times, v1.18.11 of MDS 3.0 feels more like MDS v4.0 to me.

Here is what is available so far.

The movies have been released. Have you watched the YouTube training videos yet? You should. There are 11 videos. You’ll need to prepare to spend about four hours of your time viewing all 11.

 It will be time well spent. In my opinion, CMS did a pretty good job of producing these training vignettes. 

Video 11 begins the process with an overview of the changes. The remaining videos, all the way through video one, spend significant time detailing the changes for a well-rounded engagement. 

There are a variety of revisions throughout the manual. Most of the substantive revisions and changes are related to implementation of the mandates from the Improving Medicare Post Acute Care Transformation Act, or IMPACT Act

This legislation signed in 2014 has had and will continue to have significant impact on quality reporting and Standardized Patient Assessment Data Elements (SPADEs). 

The core of the IMPACT act requires the submission of standardized data by Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), Home Health Agencies (HHAs) and Inpatient Rehabilitation Facilities (IRFs). 

It requires assessment data to be standardized and interoperable in order to allow for exchange of the data among these post-acute providers and other providers. 

Ultimately the intent is for standardized post-acute care data to improve Medicare beneficiary outcomes through shared decision making, care coordination, and enhanced discharge planning.

That seems like a tall order. But it’s happening, and MDS 3.0 v1.18.11 is taking these mandates to the next level for SNFs. The primary changes to the MDS and RAI Manual are related to the IMPACT ACT mandates. Accuracy is key and that’s where the training videos come in. 

It’s also key to understand the reporting requirements for these data elements and the incentive for reporting them. 

Currently, facilities must report 100% of the MDS data elements that are used to calculate the SNF QRP Quality Measures on at least 80% of the MDS assessments submitted to IQIES or they will lose 2% of the annual payment update (APU), or Market Basket Update. 

SNFs must also report 100% of the data for COVID and Influenza vaccination to NHSN or risk the same penalty, a conversation for another day. The point is, both standards must be met.

MDS items that are required to be reported are listed in the SNF QRP Table for RABM for the FY 2024 SNF QRP APU and the FY 2025 SNF QRP APU Table for Reporting Assessment Based Measures and Standardized Patient Assessment Data Elements.

Note that SPADEs have been added to the FY 2025 document title. When you download these two documents, you will notice that the data elements that will be required to be reported for FY 2025 APU adjustments have increased significantly compared to FY 2024. That’s due to the IMPACT Act and the standardized data elements that have been added to MDS 3.0 v1.18.11. 

It is also important to take note of the fact that in the FY 2024 SNF PPS proposed rule that was released back in April, CMS has proposed to increase the MDS based data elements reporting requirement. 

If finalized, the reporting requirement will be 100% of the data necessary to calculate the assessment based SNF QRP measures and 100% of the SPADE data elements on at least 90% of the MDS assessments submitted to IQIES. 

That’s a high bar for so many MDS data elements. CMS is serious about standardized data reporting and the IMPACT act requirements.

The changes coming our way this fall are substantial, from the data reporting requirements to the paradigm shift to health equity and social determinants of health, but that’s another conversation for another day.  It’s like an action movie that keeps you on your toes until the very end.

We still don’t know how the quality measures that are currently driven by section G will be affected by the upcoming changes. That information has been promised by CMS for some time after October 1. Perhaps a sequel of training videos is in the works.

At any rate, the training that has been provided so far is pretty good. I have noted in some of my trainings on the upcoming changes that, in preparation, we should be reading the RAI Manual like we are reading it for the very first time. 

After watching CMS’ MDS 3.0 v1.18.11 training videos, I still believe we should do that. But, having viewed all 11 videos, I’m inclined to say that the movie, while not the RAI manual, at least makes the book worth reading. 

That’s more than I can usually say about a movie that’s made about a book. Let’s get learning!

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

Have a column idea? See our submission guidelines here.

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The MDS reminds me of something in Narnia? https://www.mcknights.com/blogs/mds-intelligence/the-mds-reminds-me-of-something-in-narnia/ Tue, 16 May 2023 16:00:00 +0000 https://www.mcknights.com/?p=135108 I am a fan of C.S. Lewis. If you have not read “The Chronicles of Narnia,” you should. You may have seen the more recent three films based on these books. As good as they were, as is usually the case, the books are better.

In “The Lion, the Witch and the Wardrobe,” the second in the book series, four children find themselves in the land of Narnia. 

In Narnia, a faun called Tumnus remarks to Lucy that because of the White Witch, it is “Always winter but never Christmas; think of that!” To which Lucy replies, “How awful!”

That’s the sort of static seasonal lamentation we might all express if it were true for us. Fortunately, the story does not leave us there. It truly is a must-read!

I was thinking about Tumnus’ observation as the April Care Compare Refresh came and went. Did you notice? Surprise! There were no changes to the MDS QM thresholds. 

You may remember four years ago in QSO-19-08-NH, CMS indicated that, “Every six months, QM thresholds will be increased by 50% of the average rate of improvement in QM scores. For example, if there is an average rate of improvement of 2%, the QM threshold would be raised 1%. Similar to setting new thresholds, this action also aims to incentivize continuous quality improvement.”

Due to COVID-19, CMS put those plans on hold. However, the 5-star users’ guides that CMS posted for the April and October 2022 refreshes indicated that they had moved forward with these plans. Subsequently, the thresholds were increased in both updates.

That set a precedent. October and April would be the six-month intervals to expect these changes. And so, when Care Compare was refreshed last month, I immediately looked to see how the thresholds had changed.  

To my surprise, there was no update to the 5-star users’ guide and no notification on the 5-star preview reports regarding threshold changes So, I emailed CMS to see if I had missed something Here’s how they responded.

“CMS has planned regular updates to the quality measure (QM) thresholds every six months when there is improvement. With the April 2023 refresh, the QM thresholds were not changed because the QMs did not improve since the last rebasing in October 2022.”  

“(We) looked at the period from July 2022 to January 2023 when deciding whether to rebase in April.” 

“The rate of improvement will be measured again in October 2023, and at that time the QM thresholds may be updated if there is improvement in the QMs.”  

By the way, are you curious to know what time periods were evaluated that affected the April and October 2022 QM cut point changes? I was.

It turns out that since CMS chose to delay the threshold changes until April 2022 because of COVID, they used the time period of April 2019 to January 2022 to determine improvement. That’s a long time. For the October 2022 update, CMS used January 2022 to July 2022. 

I was also curious as to what specifically changed in the QMs themselves relative to these previous updates, so I dug a little deeper. I shared my findings in a blog post and a web presentation. I found the results very interesting. You may as well. 

That data seemed to indicate that at least some of the improvements were an artifact of COVID-19. The coronavirus naturally had a devastating effect on some QMs, like ADL-related measures and pressure ulcers. These naturally improved once COVID waned. Here’s an example.

Curious as to what timeframes will affect the October 2023 update, I continued questioning CMS. They indicated, “With the October 2023 refresh, CMS will be looking at improvement during the period of July 2022- July 2023.” 

Ostensibly, since no improvement was noted between July 2022 and January 2023, the period affecting the April rebase, CMS will evaluate for improvement for the October update using the entire year since the last improvements were noted. 

I would have liked it if CMS had somehow made us aware of their decision not to rebase the QM cut points in April, and why. But then, you wouldn’t be reading this column, and my curiosity would have been satisfied without all the effort.

Always winter and never Christmas? Well, not so much, I suppose. No change/increase in the QM thresholds is not such a bad thing. The long stay and short stay cumulative point values necessary to achieve a QM star rating will remain at their current levels through the July 2023 update at least.

Yet, it does signal that there was no national improvement in the QMs that drive the star rating thresholds. What does that mean? Time will tell. 

At the end of the day, it may be a signal for providers to spend some quality time with their own QMs. Continuous quality improvement, after all, is the reason we have quality measures.

Without that, from the resident perspective, maybe it would feel a little like “Always winter and never Christmas.” To which we should reply, “How awful!”

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

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The MDS is the ‘bee’s knees’ https://www.mcknights.com/blogs/mds-intelligence/the-mds-is-the-bees-knees/ Tue, 18 Apr 2023 16:00:00 +0000 https://www.mcknights.com/?p=133975 I may have mentioned this before: I am a beekeeper. A hobbyist, really. I started out five years ago with one hive intending to keep it a light hobby, something interesting for weekend relaxation and perhaps some honey to boot. 

It didn’t stay that way for very long. Keeping bees becomes more attractive the longer you do it.

Last season, I had eight hives in various locations around where I live. Being busy with “regular” work, that many hives were a stretch for me. It’s hard work at times, but I have gotten a taste of the sweet reward, and it is worth it.

Last summer, we all got a taste of where the Centers for Medicare & Medicaid Services is heading regarding a unified payment system for Medicare-covered post-acute care (PAC). RTI International published a report to Congress, mandated by the IMPACT Act titled, “Unified Payment for Medicare Post-Acute Care.” It’s worth a look.

Medicare PAC services are provided to beneficiaries by PAC providers defined as skilled nursing facilities (SNFs), inpatient rehabilitation facilities (IRFs), long-term care hospitals (LTCHs) and home health agencies (HHAs).  

The Secretary of the Department of Health and Human Services was mandated by the IMPACT Act to submit a report to Congress with recommendations and a technical prototype for a Unified Post-Acute Care Prospective Payment System (UPAC PPS) that would,

  • set payment according to individual beneficiary characteristics (such as cognitive function, motor function, and impairments), rather than PAC type; 
  • account for the clinical appropriateness of services furnished and beneficiary outcomes; 
  • be designed to incorporate standardized patient assessment data as described under Section 1899B of the Social Security Act; and 
  • further clinical integration, such as by motivating greater coordination around a single condition or procedure to integrate hospital systems with PAC providers. (1)

As with the Patient Drive Payment Model, the UPAC payment system prototype relies heavily on data mined from the assessment tools. The data necessary to develop this initial UPAC PPS prototype came from Hospital and PAC claims as well as the assessment tools that each PAC provider uses (HH – OASIS, LTACH – LCDS, SNF – MDS and IRF – IRF PAI).

It was from these assessment tools that much of the stratification or end splitting was derived. In fact, the UPAC PPS report to Congress indicates that, “In connection with the IMPACT Act, selected standardized self-care and mobility assessment data were collected and submitted to CMS …” (1)

Using these and other assessment data, CMS created several variables for the prototype analysis including;

  • a motor (i.e., physical) function score calculated using data from the standardized self-care and mobility data elements, 
  • indicators of bladder and bowel incontinence, and
  • a cognitive and communication function score calculated using data from the assessment data elements. (1)

Only the self-care and mobility items were considered Standardized Patient Assessment Elements or SPADEs, when this prototype was developed. These have been a standard item set consistently reported in each assessment type. In the end, they also had a more significant effect on the cost of care than the other elements. 

The other items like cognition, communication and incontinence were not standardized elements at the time of prototype development and were not consistently reported. They also did not appear to have significant impact on cost of care in the initial analysis completed for the UPAC PPS prototype. In fact, they were relegated to a subsequent phase of the prototype’s case-mix adjustment focused on comorbidities.

While the initial UPAC PPS prototype is a start RTI acknowledged that, “… universal implementation of a unified PAC payment system could not be done under CMS’s existing statutory authority.” (1) They also acknowledged that additional analyses need to be done. Part of that analysis will surely be a more robust SPADE configuration among the various assessment tools, which has begun.

We have a tremendous responsibility when completing the MDS to ensure that the data we code is accurate and reliable. Now that we have the final MDS 3.0 v. 1.18.11 with new and expanded items, as well as the DRAFT RAI Manual that goes along with it, our task is all the more important.

In a statement related to the RAI Manual release, CMS stated, “This version of the MDS 3.0 RAI Manual contains substantial revisions related to the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), which requires that standardized assessment items be collected across post-acute care (PAC) settings. Standardized data will enable cross-setting data collection, outcome comparison, exchangeability of data, and comparison of quality within and across PAC settings.” (3)

FYI, most of the data elements that are necessary to accomplish this will be complete with MDS 3.0 v1.18.11 implementation. We may soon see health equity measures, hinted at in the FY 2023 SNF PPS final rule, come to fruition. Social Determinants of Health SPADEs seem to be opening that door.

Remember also that “A goal of unified PAC payment is to base the payment on patient characteristics instead of the PAC setting. This framework applies a uniform approach to case-mix adjustment across Medicare beneficiaries receiving PAC services for different types of PAC providers while accounting for factors independent of patient need that are important drivers of cost across PAC providers.” (2)

And then this: “The unified approach to case-mix adjustment includes standardized patient assessment data collected by the four PAC providers.” (2) 

FYI, most of these data elements are already in place in the current set of PAC assessment tools. Stay tuned for UPAC PPS 2.0.

The phrase, “bee’s knees” means something excellent or wonderful. Remember, PDPM is largely a result of past MDS data. Consider the effect that the MDS has had on past payment system development. 

April is the month that I get to pick up the bees I have purchased from a local beekeeping supply store and install them in my hives. I look forward to this task every year. For a beekeeper, it is one of the many “bee’s knees” experiences we get to enjoy.  

It is true that the opportunity we have to shape a future PAC PPS is significant. The MDS can be an excellent and wonderfully powerful tool in that process — the “bee’s knees” — if we will see it that way. In the end, the sweet reward will bee worth it.

Quotation sources:

  1. Unified Payment for Medicare Post-Acute Care
  2. IMPACT Act Spotlight and Announcements
  3. CMS Email announcement about the DRAFT RAI Manual v1.18.11 release

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.

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