MDS Changes Could Have Ripple Effects on Nursing Home Readmissions, Citations

Staying informed about upcoming changes to the Minimum Data Sets (MDS) will be vital for skilled nursing operators come October, when the new changes are implemented. These changes include more finely-tuned definitions and more data collection.

Section GG of MDS, which measures the functional status and goals of residents in their self-care, mobility, and communication capabilities, is often the most widely discussed change because it will directly impact reimbursement for skilled nursing operators. However, there are other changes that operators need to be aware of as well.

Among these changes are those pertaining to the data collection process on social determinants of health. With this measure, the Centers for Medicare & Medicaid Services (CMS) recognizes the role played by social, economic, and environmental factors in health outcomes. CMS will now, for example, require data on social activity, and by extension social isolation, because it impacts mental health.

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There are also some changes related to refinements to definitions – and knowledge of these is important to avoid survey citations as well as coding and getting reimbursed correctly for services rendered.

Leah Klusch, executive director of The Alliance Training Center, said that the accurate coding of the MDS is involved in almost every aspect of the operation of a skilled nursing facility.

“If the person who’s coding on the MDS does not know all of the definitional specifics for that item, they may just code the item inaccurately, or what they put on the MDS might be in the wrong place,” she said.

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Social Determinants of Health

Executives at Health Dimensions Group, a management and consulting organization that serves senior living, post-acute, and long-term care providers, said that there are 10 different areas that are being affected by the changes to the MDS document itself, five of which are fairly major.

One of the overall new focuses of the new MDS is on social determinants of health, which will be addressed in sections A, B and D.

“Social determinants are not genetics, they’re not physical,” said Heather Haberhern, SVP of Quality at HDG. “They’re not necessarily even medical. They are the things that happen around us that really impact how we age and how our health is.”

Examples would include access to transportation, health literacy, and social isolation.

CMS is increasingly acknowledging the influence of social, economic, and environmental factors on residents’ health outcomes, and emphasizing the importance of addressing social determinants.

“It’s a very important data section and the changes really reinforce the commitment that CMS made for us in October that has to do with behavioral health,” she said.

Mary Madison, a clinical consultant for long term and senior care with Briggs Healthcare, said during a webinar this week that taking more data on social determinants of health will hopefully have a positive impact on readmissions.

“We have to know where people are coming from and where we’re going to send them back to and how we can help them go back successfully and not cause a readmission or worse for them and us,” she said.

She also discussed the interview component of MDS data collection with the resident, and how there will be an increased emphasis on collecting accurate racial and ethnic data.

“We were to interview people before but this is critical going forward,” she said. “You ask the resident to select the category or categories that most closely respond to their ethnicity. It’s not what the medical record says. It is not what you think they are from eyeballing them. You ask them to select and it can be a multiple choice. If the resident is unable to respond, you may ask a family member, a significant other and or a guardian or legally authorized representative.”

She emphasized that staff training and utilizing federal training resources can help get staff up-to-date.

“[Social determinants of health] are conditions in the places where people live, learn, work, play and age that affect a wide range of health risks and outcomes,” she said. “It affects all of us, whether we’re staff or residents or family.”

Other clarifications

Some operators have said that survey citations they have received for elopement have been inaccurate and burdensome. The new MDS includes revisions of what is considered to be a resident elopement.

Elopement refers to the act of a resident leaving a healthcare facility without proper authorization or supervision, which can pose significant risks to their safety and well-being.

The new MDS includes further specification of what kinds of behavior can constitute harm to a resident in regard to elopement.

“There was certainly a clarification of what’s considered to be elopement, you know, all kinds of additions to that plus a state form and a state process that’s now nationally controlled for facility reported incidents,” she said.

While it helps to clarify elopement, Haberhern stressed that focusing on staff retention can help mitigate accidents and elopements.

“We don’t have enough people out there to bring in and sometimes we’re keeping them for days, not for months or for years,” she said. “And it’s very hard to get them as well trained to care as deeply as we need them to and so on.”

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