Ask the payment expert: How well are the new MDS rules working?
Patricia Boyer, MSN, NHA, RN
Recently, I had the opportunity to complete several Medicare assessments. It is a very complex process to review all of these new requirements.
For example, it used to take me an hour to review a Medicare chart to see if all the requirements are met. Now, if a resident has been in the facility longer than 21 days, it takes me at least two to two-and-a-half hours to review all the requirements.
Despite the time, the Medicare assessment process is one of the most important. It is critical that staff members are talking about your Medicare residents on a daily basis, including discussion of therapy minutes and days and COT needs.
The team should make sure they are reviewing key components of the MDS accuracy by completing the MDS Triple Check prior to submission on a weekly basis. What happens if you don't have these processes in place? Not completing a COT is considered a missed assessment. According to the RAI manual, “If the SNF fails to set the ARD prior to the end of the last day of the ARD window, including grace days, and the resident was already discharged from Medicare Part A when this is discovered, the provider cannot complete an assessment for SNF PPS purposes and the days cannot be billed to Part A.”
Even if your resident is still on Medicare A when you discover this error, if it is beyond the next assessment used for payment, completing an assessment late can still result in a huge payment loss. For one facility I recently audited, missing COTs for two residents resulted in a payback of $9,500 to Medicare.
The best solution is to make sure you have the correct processes in place so assessments are always completed timely. It's not easy, but necessary.