Regulatory Update

News Release September 2022: Most Significant Change to the MDS in Twelve Years

Polaris Group Profile
Polaris Group
September 8, 2022
March 14, 2023
Polaris Group Profile
Polaris Group
March 14, 2023

On September 2, 2022, CMS posted a draft of updated MDS specifications. Here are the revisions.

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On September 2, 2022, CMS posted a draft of updated MDS specifications.  Industry leaders all agree this is the most significant change in the past 12 years. Stakeholders may recall that prior to the pandemic CMS released a similar draft version of the MDS, but the changes were placed on hold due to the challenges brought about byCovid-19.  The revisions to the MDS are not slated to go into effect until October of 2023, so the good news is that providers have ample time to begin preparing for the new requirements by providing training to their team members involved in the MDS.

CMS also published its Quality Reporting Program Quality Measures Calculations and Reporting User’s Manual Version 4.0 that directs measurements and risk-adjustments related to reporting quality metrics beginning this October.

The unknown at this time is how the new and changed MDS items will affect the payment process. Historically, CMS has increased payments for higher acuity services and exempted those higher acuity treatments from higher reimbursement.

Many parts of the MDS will not change at all. Others undergo massive overhauls.

Revisions set to change in October of 2023 include:

  1. Section G will disappear – for the most part. Some section G items have been updated and incorporated into Section GG (Functional Abilities and Goals). Some areas maintain a seven-day assessment period (GG0115ROM) and others transition to a three-day assessment period (GG0130I Personal Hygiene and GG0170FF Tub/Shower transfer). There will be more three-day assessment periods than before.
  1. Section GG headers will reflect new coding requirements on OBRA Assessments and Interim Payment Assessments (IPAs). Providers are wondering how to shift from the nurse aide documentation of the late-loss ADL’s and the application of the rule of three to relying only on Section GG and usual function.
  1. Section G goes away but proficiency at coding additional and revised items in Sections A, B, C, D, J, K, N and O will be required and will impact full market basket payment updates. Several pain related questions have been cleaned up to obtain better answer options
  1. SNF QRP Measures related to transferring health information to the patient post-acute, to the provider post-acute, to CDC NHSN which included COVID-19 and Influenza have been added.
  1. The PHQ-9 can be a shorter interview – if certain coding requirements are met.
  1. The medication list has been expanded to include antiplatelets and hypoglycemics and Section N0415 replaces Section N0410.

These changes will impact entire organizational processes in terms of who will be responsible for what and will force the MDS software industry to revise software to include all new requirements.

Providers note that CMS states this is a draft of updated MDS specifications, but with so many details released and minimal opportunity for comment, they feel this is likely as close to the final proposal as we will see.

For help on how to navigate these changes, contact Polaris Group.

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