CMS Clarifies MDS Mood Interview Changes in RAI Manual Updates

More guidance is available on how to conduct mood interview changes, with the Centers for Medicare & Medicaid Services (CMS) updating the Resident Assessment Instrument (RAI) manual to reflect key changes in the new Minimum Data Set (MDS).

Notably, if a resident refuses or is unwilling to participate in the interview, assessors need to go directly to a section in the manual on social isolation, according to manual updates. CMS also added that section D0100 should act as a “gateway” between whether a staff assessment of resident mood should be conducted, or the patient mood interview.

The MDS changes interview parameters for capturing resident depression, from PHQ-9 to PHQ-2 to 9. Now, a resident’s answers to the first two questions determines whether the subsequent questions will be asked, or if the mood interview will immediately end.

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“This is big … this came out of nowhere on the first errata and has been clarified with this second release,” said Joel Van Eaton, executive vice president of PAC regulatory affairs and education at Broad River Rehab.

In a review of 2 million MDS assessments, Zimmet Healthcare Services Group and Simple LTC determined that the number of assessments resulting in a depression end-split would have fallen by 18% under the new system.

The depression end-split triggers a reimbursement increase under Medicare Part A, a roughly $40 per day increase to the nursing component under the Patient Driven Payment Model (PDPM).

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“It will be interesting to see the effect this change has on PDPM reimbursement,” said Van Eaton. “Now, the only time that facilities will be able to experience this additional funding for depressed patients when they are unable to participate in the PHQ-2 to 9 is if they are rarely or never understood as coded at item B0700, Making Self Understood.”

Section D0100 refers to whether a resident mood interview should be conducted. Staff must speak with the resident in their preferred language and ensure the resident can adequately hear, or if they’d prefer to communicate a different way; sign language, in writing or pointing to signs were given as examples of alternate modes of communication.

If the staff determines the resident is not interviewable, scripted interviews with staff who know the resident well should provide critical information on understanding the resident’s mood and making care planning decisions, according to the manual.

“The assessor will complete the Staff Assessment only when D0100 is coded 0, No. The assessor does not complete the Staff Assessment based on resident performance during the Resident Mood Interview,” according to CMS guidance.

The staff assessment for mental status is also allowed when there is an unanticipated discharge for a Part A resident, Van Eaton noted.

In a section detailing a resident’s return to the community, CMS added a step-by-step process for the facility to use so that the resident has the opportunity to discuss returning to the community. This process is triggered if a return to care area assessment (CAA) is triggered.

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