With the looming changes to the Minimum Data Set (MDS), industry experts said now is the time to take advantage of resources or harness new technologies to make sure MDS reporting is being done accurately.
The Centers for Medicare & Medicaid Services (CMS) has announced changes to the MDS and the Five-Star Rating System, which will be implemented on October 1. An even more detailed MDS, complete with changes to timelines and measurements, will require extra training, and it is sure to impact the ways in which skilled nursing operators teach clinical staff to report such data.
With that in mind, experts said it is important to focus on three broad areas of change – social determinants of health, health equity, and quality measures – and to have experienced members of the clinical staff train employees on detecting discrepancies in residents’ strengths and needs during MDS assessments across disciplines.
After all, these discrepancies can result in costly coding mistakes, and while new technologies to address coding discrepancies have burgeoned recently, it all begins with human error. And so, operators will need to find ways to train staff better on the MDS changes despite workforce challenges. MDS includes information on demographics, clinical measurements, clinical diagnoses documentation, and items that identify the patient’s experience, which are summarized into codes.
Among other changes, CMS is removing Section G, which is used to measure the functional status of residents. The move to replace it with a similar Section GG has states scrambling to address the fact that Section GG pulls rehabilitation services into a separate case mix component, while resource utilization groups (RUGs) incorporate it into the case mix with the rest of the clinical conditions.
Leah Klusch, executive director of The Alliance Training Center, said that this summer will be important for operators to make sure they are prepared for the upcoming changes and train staff accordingly.
“We’re going to move to this even more technical MDS in October with many new items, with many new definitions, and some new timelines that we’ve never used before,” she said, adding that the new manual includes 400 more pages of information. “Now some of those are relatively minor things, but the majority of them are new words, new timelines, and new measurements.”
Joel VanEaton, executive vice president of PAC Regulatory Affairs and Education at Broad River Rehab, told Skilled Nursing News that the connection between MDS 3.0 and the changes that are occurring in the proposed rules in large part have to do with social determinants of health, health equity, and quality measures.
“We’ve got a new bonus structure being proposed for value based purchasing,” he said. “And so identifying those social determinants of health and being able to incorporate that into the understanding of health equity are really important.”
“We have a way to summarize those codes into functional codes and experiential codes,” Klusch said. “Part of those are the interviews, the mood interview and the pain interview. So we actually are looking for unique information for that elder alone.”
Data completeness
There are over 200 items on the MDS that feed the payment system through the Medicare Part A payment system, and in states that have a case mix there is another set of items from the MDS related to Medicaid payments.
“When there are light omissions or something is coded wrong or something’s coded on the MDS that is not reproducible in the record, we can’t go back and justify it,” Klusch said. “The facility can then lose significant money in the payment process.”
Tammy Tuminaro, CEO of Century Rehabilitation, which provides therapy services to skilled nursing and outpatient facilities nationwide, said her team is developing a new technology to address some of the discrepancies in MDS assessments.
Tuminaro said the technology evaluates both the nurse assessment and the therapist assessment of a patient to compare them both and check them for discrepancies.
“It’s not being utilized to say what is or isn’t correct,” she said. “It’s more utilized to say, ‘Hey, there is a discrepancy here. You guys need to discuss this.’ At the end of the day, nursing and therapy looks at the two assessments to see if maybe we need to go back to therapy, maybe you need to go back to nursing, maybe you need to go back and reassess this individual just to make sure that we’ve got everybody on the same page.”
Yet at the end of the day, Klusch said, there are many technologies being developed to interpret MDS data, but none of them replace the importance of training staff on changes.
“We have a significant problem with MDS data completeness and that it’s that the actual observation is made of the elderly and it’s actually included in the assessment,” she said.
Getting staff up-to-date
Klusch said that because of staffing stresses, operational stresses on the industry, and Covid, some clinical staff have moved away from referencing the Resident Assessment Instrument (RAI) manual for their definitions.
“A lot of them are trying to fill out the MDS from memory and memory fails, especially when it’s real technical, and so we have a lot of mistakes,” she said.
Looking at reports that come out on the MDS data for facilities, Klusch said, she can pick out pretty quickly if there are data issues. There are certain expectations for mental health of people who are admitted to rehab centers or skilled nursing facilities from the hospital. They tend to have issues with being sad, depressed, or worried about their future during the first seven days when the interview is conducted.
“If the interview scores don’t indicate the elders’ feelings of just how many adjustments that they have to make, that’s a dead giveaway,” she said.
Klusch said that since MDS is an interdisciplinary document, it means that the team has to work together.
“The team in the building, the interdisciplinary team, social service, dietary, nursing, therapy, and all the other administrative pieces that go with that,” she said. “All of those, all those individuals have to recognize that they’re part of a team and they have to look at things in the same way using the same definition.”
As a consultant, Klusch said she looks at data quality measures on an individual basis, such as if a person is improving in function or if they have other clinical comorbidities that need to be watched carefully, like pulmonary disease, hypertension, diabetes and infection.
“A very important part of good operations right now is to be able to help the MDS manager, the financial manager, and the operations people to pick up where to be able to identify where things on the MDS are not reproducible in the medical record,” she said.
Companies featured in this article:
Broad River Rehab, Century Rehabilitation, The Alliance Training Center
