Nursing home operators expressed frustration with Minimum Data Set (MDS) changes effective Oct. 1, with many concerned that they will be out of compliance with completion and submission requirements because of error codes.
Errors are stemming from software vendors, and providers are unable to submit MDS data with proper coding information, nursing home operators said during the Centers for Medicare & Medicaid Services (CMS) Open Door Forum on Thursday. Software hasn’t been programmed properly, and operators say they are left between a rock and a hard place – transmitting an inaccurate MDS or being out of compliance.
“Currently, it seems like all the vendors are having issues. No one is able to get proper HIPPs [Health Insurance Prospective Payment System] codes and so we are going to be out of compliance. Is there anything that we can do about it?” one caller said.
For the most part, CMS officials suggested operators reach out to their software vendors and Medicare Administrative Contractors (MACs) for these issues, or contact the Internet Quality Improvement & Evaluation System (iQIES) help desk.
Operators were also directed to Chapter 6, Section 30.1 of their claims processing manual – SNFs that submit claims without completing the MDS process will not be paid, according to John Kane, SNF team lead at CMS. But, it’s important to remember that the record will be accepted into the state RAI database even if the calculated RUGs code differs from the submitted values, he said.
The error will be flagged in the final validation report by issuing a warning message and listing the correct code. When a discrepancy like this occurs, the code used on the final validation report will be used for billing purposes, he added.
“I hope that this helps you address some of those earlier questions in regards to when there is a discrepancy between what the vendor software is calculating versus what is being provided on the final validation report,” said Blum. “Our claims processing manual states clearly that the code that is provided on the final validation report is the one that ought to be used.”
Another caller suggested CMS issue an updated technical specification guide for submitting to iQIES that addresses the coding confusion.
If CMS finds that there are “quite a bit of issues” tied to MDS changes and coding, the agency will issue an errata document in the coming weeks, CMS’ Kim Jasmin told operator attendees of the forum.
Aside from the MDS discussion, CMS officials also reviewed a correction notice to the 2024 SNF PPS final rule – there was a technical error in the calculation of the wage indexes. Correcting the error required CMS recalculate the wage index budget neutrality factor, which caused a “very minor” revision to the unadjusted SNF PPS federal per diem rates and the case mix adjustments to the PPS rates.
The same correction notice delved into typographical errors related to the PDPM ICD-10 code mappings made available on the CMS website.
“We identified some codes that were erroneously added, noting that the addition of any ICD-10 code to the SLP – or speech and language pathology – comorbidity list would amount to a change in policy that would first need to undergo notice and comment rulemaking,” said Tammy Luo, another SNF team lead with CMS. “We have made the correct file available on the CMS website and would note that the preamble language of the fiscal year 2024 SNF PPS Final Rule discussing ICD-10 mappings is unaffected by these errors.”
Operators were unable to ask questions about the proposed minimum staffing rule during the call, while many other questions related to MDS and policy changes were directed to separate email addresses instead of being answered live.
Key CMS officials were unable to be on the call due to illness, Kane said, but the Q&A portion of the forum, including questions answered offline, will be posted in a couple weeks to the CMS podcast and transcript webpage.
Companies featured in this article:
