The Centers for Medicare & Medicaid Services (CMS) recently held a two-day provider training in Baltimore, Maryland, on upcoming changes to the Minimum Data Set (MDS) 3.0 related to the Skilled Nursing Facility Quality Reporting Program (SNF QRP). Changes include new additions, retired items and items transitioning to state optional completion with the MDS 3.0. All changes to the MDS 3.0 will be effective October 1, 2018. The Resident Assessment Instrument (RAI) Manual hasn’t been updated, but the CMS representatives at the training indicated the updated RAI Manual with coding instructions for the new MDS 3.0 items would be available in early September.
MDS 3.0 Version 1.16.0R will be effective as of October 1, 2018. There’s an item change document contained in a downloadable zip file that explains which items were changed from the draft version 1.16.0 to the final version 1.16.0R.
Sections affected by the changes are outlined below.
New items related to prior functioning of everyday activities and prior device use have been added to Section GG as items GG0100 and GG0110. Four new self-care tasks (GG0130) have been added and include the ability to shower/bathe self, upper and lower body dressing and putting on and taking off footwear. Eight new mobility items have been added in GG0170 to include the resident’s ability to roll left and right, car transfer, walk 10 feet, walk 10 feet on uneven surfaces, go up one step or curb, take four steps and 12 steps and pick up objects from a standing position.
New item I0020 will now require coding of the resident’s primary medical condition that best describes the primary reason for admission. The provider will have 13 categories to choose from. If the resident’s primary medical condition isn’t represented in the listed categories and falls in the category of “Other Medical Condition,” an ICD-10 code for that condition will need to be listed in I0020A. This will be a challenge for most providers, as SNFs don’t employ certified coders and will need to ensure the person responsible for diagnosis coding is knowledgeable and understands the ICD-10 coded used in each category in Section I0020 and I0020A.
Item J2000 in health conditions has been added as a risk adjustment question for SNF QRP measures and will inquire as to whether the resident has had any major surgery during the 100 days prior to admission.
Several items in Section M are being retired, which will be a welcome relief to providers. Retiring items include: date of oldest stage 2 pressure ulcer in M0300B, measurements of stage 3 or 4 pressure ulcer in M0610, most severe tissue type, worsening of pressure ulcers in M0800 and healed pressure ulcers in M0900. The guidance for coding unstageable pressure ulcers with eschar on a pressure ulcer that was previously coded as present on admission was also amended.
The term pressure injury was added to Section M, along with pressure ulcer in accordance with National Pressure Ulcer Advisory Panel (NPUSP) guidelines. The term “suspected” has been removed from “deep tissue injury” in M0300G.
Section N has been updated to conform to collection of information for the SNF QRP measure of Drug Regimen Review. Three new items were added to include drug regimen review and follow-up of identified issues on admission and medication review intervention on discharge.
Item labeling changes will take place in Section O for items O0100F and O0100G. O0100F will now be Invasive Mechanical Ventilator (ventilator or respirator) and O0100G will display as Non-Invasive Mechanical Ventilator (BiPAP/CPAP).
State Optional Items
CMS will no longer require the completion of Column 1 (While Not a Resident) for mechanically altered diet (K0510C), therapeutic diet (K0510D) and proportion of total calories and fluid intake by artificial route (K0710A and K071B) in Section K. However, some states may continue to require completing these items. We recommend providers check with your state RAI coordinator for your state’s requirements for completing these items.
Several of the MDS 3.0 item changes will only be required on Medicare Part A assessments upon admission and discharge and are directly related to the SNF QRP. The current assessment-based measures are:
- Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) (National Quality Forum (NQF) #0674)
- Percent of Patients or Residents with Pressure Ulcers That Are New or Worsened (NQF #0678)
- Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
Providers must submit all necessary data to calculate the SNF QRP measures on at least 80 percent of the MDS assessments submitted through the Assessment Submission and Processing (ASAP) system to the Quality Improvement Evaluation System (QIES). SNFs that don’t have 100 percent of the required data submitted on 80 percent of the MDS assessments will receive a 2 percent reduction to the annual payment update for FY 2020. Data collection periods for the SNF QRP are:
The Quarter 1 deadline is fast approaching and providers should check the Review and Correct Report for each measure, as well as the Resident-Level Report. The Review and Correct Reports can be found in the Certification and Survey Provider Enhanced Reports (CASPER Reporting) in the CMS QIES System.
BKD will host a webinar on September 7 about this update—an invitation will be coming soon to clients and BKD Thoughtware® subscribers. In the meantime, contact Suzy or your trusted BKD advisor if you have questions concerning the SNF QRP and MDS changes or accessing the provider reports.