The latest version of the MDS Resident Assessment Instrument (RAI) manual released early Monday contains “substantial revisions,” according to a statement issued by the Centers for Medicare & Medicaid Services (CMS).
In keeping with the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), the new draft includes standardized assessment items that need to be collected across post-acute care settings, allowing for comparison of quality and outcomes within and across all such settings.
For Lorie Morris, SVP of assessment coordination at Prestige Healthcare, there weren’t any surprises in the latest version. It simply provides more details and clarity, and Morris applauded the update.
Revisions allow providers to look beyond just what the patient is telling them too, with standardized assessment language.
In the latest revision, not only is standardized language incorporated for Section GG – used to measure the functional status of residents – but also Section A, which is used for collecting clinical information, Morris said. And then the discharge process and medication reconciliation is updated as well, she said.
“We’ve all been waiting, holding our breath, you know, not sure because of how many things have been pulled back and forth … now we have it, and now the final planning can occur,” said Morris. “It’s linking us more to the care continuum. I personally love that.”
It’s very transformative from the care provider perspective, she added. It’s challenging different care providers, long-term care being one of them, to find a way to change the wording they’ve always used, the way they’ve always done things.
Morris sees wording shifts more closely aligning with what is already in place for home health: “I think it will be a little easier for home care,” she said.
Joel Van Eaton, EVP of post-acute care regulatory affairs and education at Broad River Rehab, agreed that the meat and potatoes of Monday’s update is in the volume of clarification.
From the patient perspective, MDS changes offer more ownership, more autonomy to follow their care over time and across multiple settings, Morris said. Surveyors and entities outside of the SNF setting will get a better idea of any care setting hiccups, she said, and create a smoother shift for residents as they go from one part of the care continuum to another.
In terms of states incorporating these changes, Morris said it’s incumbent on them to figure out how they’re going to incorporate them. Some states, such as Wisconsin, Ohio and Illinois, have already taken clear steps toward MDS changes.
“It does give [states] the answers. It’s written in stone, it’s final,” said Morris.
A completely separate optional state assessment package will be released late April or early May, added Van Eaton.
“We’ve got two things coming down the road … that was a surprise to most of the people that I’ve spoken with, that that’s going to be a separate thing,” said Van Eaton.
CMS might make grammatical updates from this point on, she said, but likely nothing as substantial as what was released on Monday.
The changes take effect Oct. 1, 2023.
New assessment language
Discharge planning questions were added in the latest revision, she said, related to how care settings would share patient documents upon release. Transportation and social isolation assessments are also new to the MDS manual, she said.
“We already have processes in place, but I think [we’re] going to have to be re-educated,” said Morris. “We’re going to have to go back and look at our discharge planning and everything we’re doing to make sure it’s lined up with the specific things that are added to the MDS, using those definitions.”
Section D, she said, includes questions to assess how the patient feels about being isolated, not from an infection control standpoint but from a social standpoint.
Another big shift is related to health literacy, Morris said, and ways to gather socio-economic patient information. Language in the manual was changed to be gender neutral as well.
“[Health literacy questions are] more about understanding if the patient or their family member can understand and learn, adapting how we are communicating and educating with them to empower more involvement, ownership of their care from the patient perspective,” said Morris. [Health literacy] was on the draft items … they just sent out the reasons, the definitions, the clarity behind it.”
These new questions and assessments are all ways for CMS to better incorporate social determinants of health, Van Eaton said. The right questions around health literacy, transportation and social isolation will help clinicians better engage with the resident population, he said.
Such questions will help give providers a deeper understanding of the outcomes patients want to achieve.
In practice, this means operators will have to figure out ways to ensure and document that the patient and family understands the services being provided, rather than just handing them paperwork.
“That may not be good enough. We’re trying to figure out what those strategies will be,” said Morris.
Advice for SNF operators
Morris’ advice to operators: work with your software vendor. Get timelines on when vendors will expect the new language, questions and assessments to be in their systems.
“I think they need to analyze the questions that have changed or been added to their current workflow,” said Morris. Prestige is working with PointClickCare to this end, she said, and developing new education for nursing assistants on proper documentation.
Meanwhile, Van Eaton urges operators to devote time to reading the manual from top to bottom, and not rely on third party sources alone to relay information.
Don’t just take what you hear from people in a webinar or a training session, he advised, and don’t become passive. Operators must continue to familiarize themselves with changes through every resource available.
“If all you do is read through the red, that’s going to be the important thing. Along with that, participate in as much training as you can,” said Van Eaton. “CMS is going to do [training]. I know a lot of other organizations, including our organization, are going to be doing that. It’s going to be important that we all enter into that discussion in some way so that we can hit the ground running in October.”
CMS Open Door forums are a treasure trove of information too, he said, with the next slated for 2 p.m. EST, April 13 with a focus on MDS changes.
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