Q: We’ve been trying to fill an open MDS position and have an LPN applicant who would be great in the role. Can an LPN fulfill requirements and sign assessments?
A: A knowledgeable and organized LPN can be a valuable addition to your MDS department and fulfill many of the position’s responsibilities. But there are some requirements that only an RN can meet.
Federal regulations at §483.20(h)-(i) tell us that a registered nurse must conduct or coordinate each assessment with the appropriate participation of health professionals and sign and certify that the assessment is completed.
Nursing homes are left to determine who should participate in the assessment process, how the assessment process is completed, and how the assessment information is documented, while remaining in compliance with regulations and the instructions in the RAI manual.
“Appropriate participation of health professionals” can involve multiple interdisciplinary team members, not limited to a social services designee, dietician, activity director, and, you guessed it,
LPNs/LVNs.
Many facilities have successfully employed LPNs in lead MDS positions. In these cases, it’s up to the facility to determine how the RN will coordinate and complete the process.
If you are lucky enough to have more than one nurse in the MDS department, only one needs to be an RN who will sign all MDS assessments as they are completed. Other facilities rely on varying RN nurse managers to meet this requirement, such as the director of nursing, assistant director of nursing, etc.
Do make sure that this requirement is taken seriously. Civil monetary penalties will be imposed if anyone other than an RN signs the MDS as completed at Z0500.
Please send your payment-related questions to Eleisha Wilkes at [email protected]
