CMS Focuses on Resident Mood Interviews in Newly-Issued Nursing Home MDS Draft

The Centers for Medicare & Medicaid Services (CMS) on Friday issued its draft Minimum Data Set (MDS) — earlier than the federal agency’s typical timeline and with less sweeping changes compared to past years.

Changes, effective Oct. 1, include an update to the list of state RAI coordinators, MDS automation coordinators, CMS locations and contacts, the agency said in a memo. Revisions were also made to provide clarity and additional guidance for Section D and Chapter 6 – dealing with resident mood interviews.

Specifically, additional guidance was added around the question, “Should Resident Mood Interview be Conducted?” which serves as a gateway item for the resident mood interview, or PHQ-2 to 9 and D0500, or staff assessment of resident mood.


Minor corrections were also made to care area assessment requirements, and on guidance for combining Omnibus Budget Reconciliation Act (OBRA) discharge assessments. CMS updated an Internet Quality Improvement & Evaluation System (iQIES) warning error message in Chapter 5 of the MDS, and updated screenshots in Section A and O along with the MDS Item Matrix.

“It looks like the data sets are getting cleaned up for consistency,” said Joel VanEaton, executive vice president of post-acute care regulatory affairs and education at Broad River Rehab. “These are certainly not the mammoth changes we just experienced.”

VanEaton noted the change in the federal agency’s release schedule. “It’s interesting that CMS is releasing this so early. Most likely folks won’t really pay attention to this until closer to implementation,” he said.


It will be helpful when CMS releases the revised RAI Manual with instructions on draft changes, he added.

CMS hinted at these updates in its last Open Door Forum in December along with other possible updates, which included changes to survey testing for skilled nursing operators.

At the time, the agency said revisions to MDS would be small, with three changes involving anticonvulsants, self-care and mobility, and Covid vaccination status for residents.

There’s quite a bit more than was detailed in the CMS forum last month, added VanEaton.

Anticonvulsants will be added to the high risk drug class in Section N, since such medications are being administered to residents, CMS officials said in December. The self care and mobility discharge goal column in Section GG – GG-0130 and GG-0170, column two – will be removed as well.

A new item will be added to collect Covid vaccination status among residents, agency officials said in December. The data will be used to inform the “Covid vaccine percent of patient residents who are up-to-date” measure for the SNF Quality Reporting Program (QRP).

The last two changes are the result of policies finalized last year in the fiscal year 2024 Skilled Nursing Facility Prospective Payment System Final Rule.

On a more technical note, CMS health insurance specialist, Ellen Berry, said in December that the iQIES MDS user interface has been replaced by jRAVEN software. The new interface doesn’t allow for completion of MDS assessments for other insurance payers including Medicare Advantage and private insurance, or for other purposes.

“The take home message is that providers who need to complete assessments for other purposes, other than federal and state, should use vendor software. Providers are not to submit these assessments to IQIES,” said Berry.

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