This blog is part of Polaris Group's Decoding the MDS 3.0 series which explores changes to the new MDS, launching October 1, 2023.
On October 1, 2023, the new MDS 3.0 will become effective and present major changes to many sections and revised coding procedures. Facilities will need to prepare now for the changes occurring in various sections. This blog is part of Polaris Group's Decoding the MDS 3.0 series which will explore the changes occurring in specific MDS sections.
Section G is out, and Section GG is in: Are you ready?
Out with the old and in with the new! With the Centers for Medicare and Medicaid Services (CMS) announcement of the modified MDS 3.0, one of the areas facilities may be most apprehensive about is Section G and GG. In the revised MDS 3.0, Section G is almost completely eliminated with selected questions regarding functional limitations in range of motion and mobility device use moving into section GG “Functional Abilities and Goals”.
- Changes in coding. Section G of the current MDS assesses resident function status and is used in the calculation of quality measures. This section was most typically completed by therapists and nurses as it included items about functional abilities and goals. Previously, assessment of items focused on the resident’s level of prior function, admission performance and discharge goals. Now, discharge performance and performance throughout the resident’s stay will also be assessed. Facilities need to consider how best to train CNAs to document so that resident usual function throughout the stay is captured in order to complete Section GG.
- Documentation is key. Most pressing, however, may be the ongoing issues most facilities experience with coding accuracy and documentation. Section G coding inaccuracies are persistent and if facilities are continuing to struggle to code Section G now, it is highly likely that Section GG will pose greater challenges for accurate and timely documentation. As a result, a major question for facilities is how best to prepare staff to accurately document and code Section GG.
What to Expect
- Increased need for staff education. Facilities need to be prepared for Section GG changes in October through cross-training and staff education. To ensure accurate coding, facilities need to determine procedures to help various disciplines share information about residents so MDS sections can be completed accurately. Facilities will need to think about using CNAs to document tasks such as eating and toileting to prove that care was provided. To be able to code that accurately, you must have good documentation to capture the care provided.
- Section G will still need to be completed for Medicaid reimbursement. If your facility is in a state that uses Resource Utilization Groups (RUG) scores to determine Medicaid reimbursement, you can anticipate a major change in the Medicaid payment system. Facilities have to keep Section G for the Optional State Assessment (OSA) to receive their RUG. With Section G eliminated, many states are considering moving to PDPM for reimbursement (and they will have to eventually as there is a hard stop to Section G in Medicaid in 2025). But for now, there likely will be wide variation in payment methods across the country. These changes from a Medicaid case-mix perspective may impact revenue.
- Uncertainty around Care Area Assessment triggers. Unfortunately, many questions around the implementation of Section GG remain unknown. Right now, many of the Care Area Assessments are triggered by documentation in section G. With that section going away, it is unclear what will trigger the Care Area Assessment. Further, with many Quality Measures in the Five-Star program relating to section G, the merger of G into section GG could affect Five-Star ratings. The result is uncertainty about the impact of Section G and GG changes on facility metrics and resident care.
Recommendations from Polaris
To prepare, facilities need to be up to date on the proposed changes to the Resident Assessment Instrument (RAI), attend CMS webinars, and seek guidance from Polaris consultants who can help best prepare your facility for the myriad changes that are coming.
If your current MDS coordinator could improve Section GG coding or does not have the time or resources to train others in Section GG coding, Polaris Group can help. Our MDS center of excellence can perform chart audits and lead intensive coding training to improve the accuracy of your MDS submissions. Alternatively, our outsourced MDS coordinators can provide your facility with an experienced coder with strong communication, documentation, and collaborative skills who can support your team.