Ask the payment expert ... about the observation stay loophole

Can you explain the new MDS Section and assessment?

In March, the Centers for Medicare & Medicaid Services informed skilled nursing facilities that they would be implementing new Quality Measures effective April 1, 2016.  

One of those measures includes percentage of short stay residents who made improvement in function. This measure incorporates information that is not presently collected on the MDS 3.0. The addition of Section GG of the MDS incorporates the mid-loss ADLs of transfer, locomotion on unit and walk in corridor. 

In addition, the measurement evaluates the function from time of admission to Medicare to discharge with return not anticipated. This necessitates the addition of another assessment called a Discharge from Medicare assessment. The addition of this assessment could also result in some negative effects to RUGs Medicaid Case Mix Index (CMI) scores.

Although the new Quality Measures went into effect April 1, the new Section GG and the new Discharge assessment will not be implemented until October 1.  In addition to these measures, more  claims-based measures and MDS quality measures will be put into effect. 

All of these measures will be posted on the Nursing Home Compare website and several will be included in the SNF Value Based Purchasing initiative, which will affect your facility payment incentives in the next few years. 

You should be learning about these quality measures, beginning to track them in your own facility and including them in your quality metrics dashboard that you can share with others. That may include consumers, referral hospitals, health systems, managed care companies and accountable care organizations.