In skilled nursing facilities, accurate coding of discharge status on the MDS is far more than a clerical task.
In skilled nursing facilities, accurate coding of discharge status on the MDS is far more than a clerical task—it’s a decision with ripple effects across compliance, reimbursement, operational workflows, and the facility’s Quality Measures (QMs) and Five-Star rating.
At the core of this issue is a deceptively simple MDS item: A0310F – Discharge Reporting. This item requires the facility to indicate whether the resident is expected to return to the facility within 30 days. The response – 10/Discharge – Return Not Anticipated or 11/ Discharge – Return Anticipated, sets off different reporting, tracking, and regulatory pathways. Yet, facilities frequently struggle with consistent and compliant use of this field.
The Regulatory Foundation
According to the RAI Manual, a "Return Anticipated" discharge means the resident is discharged with the expectation of returning to the same SNF within 30 days. This includes discharges to the hospital, other SNFs, or IRFs, as long as the discharge plan includes an expected return within 30 days.
By contrast, "Return Not Anticipated" is used when the resident is not expected to return, or the return is uncertain or unlikely. This includes long-term placement elsewhere, family declining further SNF stay, or the resident transitions to home without a plan to return.
The interdisciplinary team must collaborate to determine if the resident’s discharge was planned or unplanned (A0310G). A planned discharge reflects intent for the resident to return to the facility or to DC to anticipated DC setting as coordinated by the resident’s care team, while an unplanned discharge signals a more permanent transition, such as a discharge against medical advice, a transfer to the hospital or emergency department in order to stabilize the resident, or the resident unexpectedly deciding to go home or to another setting earlier than the date the IDT feels resident is able to discharge at their highest functional level.
If the facility is unsure whether the resident will return, and if there is no formal plan or communication indicating return, the discharge should typically be coded as Return Not Anticipated to ensure accurate quality reporting and to avoid compliance risks.
Why It Matters To Code This Correctly
1. Compliance Risk
MDS data feeds directly into Medicare billing, survey findings, and state/federal reports. Misreporting a discharge as “return anticipated” when no documented plan exists can be seen as noncompliance with RAI coding standards, exposing the facility to citations under F-Tag 641 (Accuracy of Assessments).
Example: A resident is sent to the hospital, and the family informs the team that they plan to seek long-term care placement elsewhere. If the DC is still coded “return anticipated” without documentation to support the expectation of return, it may trigger audit findings or survey deficiencies.
2. Operational Inefficiencies
Incorrectly coding “return anticipated” requires the facility to track readmissions for 30 days, adding unnecessary work.
3. Quality Measures and 5-Star Ratings
Perhaps the most overlooked impact is the effect on Quality Measures (QMs) and the CMS Five-Star Quality Rating System.
- Residents that are coded as “return anticipated” who don’t return within 30 days are excluded from certain long-stay QM denominators, affecting:
- Functional decline
- Antipsychotic use
- Pressure ulcers
- These residents do not trigger short-stay quality measures if they do not return to the facility.
- Repeated exclusions or skewed denominators lead to incomplete or inflated quality performance data.
- CMS may also infer higher resident instability if discharge patterns are inconsistent, especially during audits of rehospitalization or return-to-community metrics.
Example: A resident is discharged home under financial pressure after 20 Medicare days, with no clear plan for returning. If coded “return anticipated” but no readmission occurs, this exclusion may artificially lower long-stay QM rates, raising questions during survey or quality reviews.
- Residents that are coded “Return Not Anticipated” are included in applicable short-stay QMs and affect the facility’s publicly reported outcomes if a negative event, such as a pressure ulcer or functional decline, occurred prior to discharge.
Recommendations for SNF Teams to Ensure Accurate Discharge Coding and Mitigate Risk:
1. Implement Clear Interdisciplinary DC Planning
- DC coding should not be a solo decision.
- The interdisciplinary team, including nursing, therapy, social services and the physician should determine and document the discharge plan and intent to return status in the medical record and DC summary.
2. Educate MDS and Nursing Teams
- Train on RAI guidelines for A0310F with real-world examples.
- Emphasize the 30-day window and importance of documenting intent to return.
3. Recommended Documentation & Best Practice
- Clearly document the reason for discharge, including expected return date or plan, if applicable.
- “Resident is expected to return on [date] after [reason]”
- “Resident is not expected to return based on care needs/placement plan”
- Reference discharge planner, MD, and IDT notes
- Avoid vague language such as “maybe”, “possibly”, “if needed” without a formal plan.
- Reference the code (Return Anticipated, Return Not Anticipated) in progress notes and DC reports.
- Consider interdisciplinary team input, especially from nursing, rehab, social work, and discharge planning.
- Review discharge coding for accuracy during weekly IDT, QAPI meetings or include in the information discussed in your facility’s Daily PDPM Huddle Meeting.
- Regularly train staff on RAI and QM implications to prevent inappropriate coding.
4. Monitor Trends Through QAPI Integration
- Regularly review trends in discharge coding as part of your facility’s Quality Assurance and Performance Improvement (QAPI) Program.
- Track the number of discharges coded as “return anticipated” where the resident did not return within 30 days.
- Analyze patterns by payer type, diagnosis or discharge setting to identify systemic issues or training needs.
- Use findings to drive root cause analysis and to develop targeted action plans to improve documentation, care transitions and interdisciplinary communication.
- Incorporate discharge coding accuracy as a standing agenda item in monthly QAPI meetings to ensure continuous oversight and alignment with facility-wide QAPI goals.
Closing Thoughts
In today’s post-acute environment, where regulatory scrutiny and performance-based measures shape reimbursement and reputation, accurate discharge coding is not optional but is a priority. The distinction between “return anticipated” and “return not anticipated” on the MDS is more than a coding detail; it reflects the clinical intent, discharge planning integrity, and coordination across the interdisciplinary team.
When coded correctly, this single item strengthens compliance, enhances data accuracy, and ensures reliable Quality Measure reporting—all of which influence a facility’s Five-Star rating and public profile. When misused, it can lead to unnecessary audits, skewed quality data, and operational inefficiencies.
High-performing SNFs recognize this as a strategic decision point, embedded in both clinical practice and QAPI oversight. By aligning coding practices with regulatory guidance and actual discharge planning, facilities not only protect themselves—they elevate their care delivery and sustain their operational excellence.
Ensure your discharge coding is accurate and compliant—partner with Polaris Group today.
