The Centers for Medicare & Medicaid Services (CMS) on Monday dropped the eagerly anticipated optional state assessment (OSA) for nursing homes, as a supplement for operators to fill out in states still transitioning to the Patient Driven Payment Model (PDPM).
If a state decides not to transition to a PDPM-based Medicaid case mix with the implementation of the Minimum Data Set 3.0 v1.18.11, then providers will have to complete the OSA. The new MDS is set to take effect Oct. 1.
“The OSA is not a federally required assessment; rather, it may be required in some states for payment purposes,” CMS said on its MDS informational webpage. “Each state determines whether the OSA is required and if so, when the assessment must be completed.”
Facilities are encouraged to contact state survey agencies for questions regarding the completion of the OSA.
The OSA would make information available to maintain legacy (Resource Utilization Group) RUG systems, according to Joel Van Eaton, executive vice president of PAC regulatory affairs and education for Broad River Rehab.
That also means more paperwork for nursing home staff, he said.
“Since the OSA is a stand alone assessment that cannot be combined with any other assessment type, this will be an added assessment to the required federal assessment schedule,” said Van Eaton.
Shawna Rainey, vice president of clinical reimbursement at Ignite Medical Resorts, said the OSA appears to be very similar to the Interim Payment Assessment, or IPA, used in PDPM but with a few major differences tied to Section D in the Resident Assessment Instrument (RAI) Manual. Resident mood screenings will now be assessed through differences in the PHQ-9 interview questions.
“I think our biggest challenge will be understanding and deciphering the different requirements and instructions not only across the item sets, but across the states,” Rainey said in an email to SNN.
The OSA is a temporary solution with an expiration date some time in 2025.
Moreover, when it comes to major changes anticipated with the MDS, providers in states still utilizing RUGs will need to do two assessments – one for MDS under PDPM and another under RUGs.
These major changes include a shift from Section G to Section GG – which measures resident function as well as those related to section D.
“Providers in these states [will] be required to do an additional assessment, but they will also have to keep the PHQ-9 interview instructions [in section D] separate for the OSA [versus] the federal assessments,” said Van Eaton. “This applies to all other items that have been revised in v1.18.11.”
Since Section G is maintained in the RUGs assessment, providers will need to maintain use of the “rule of three” to code this section, according to Van Eaton. For federally required assessments, providers will need to also utilize “Usual Functioning” guidelines in Section GG.
Rule of three refers to coding activities of daily living (ADLs). If an activity occurs three or more times at any level of care, providers are instructed to code at that level.
“We see Section G instead of GG and therapy minutes on the OSA item set as significant drivers of the RUG-based payment models,” added Rainey.
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