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Preparing for Section GG

Kim Lewis
Kim Lewis

Although it is not yet clear when there will be a final version of the details related to the newest addition to the MDS, Section GG, Functional Abilities and Goals, it is clear that this is going to be a reality on October 1 of this year.  

We know enough about the new section to know it's not a minor change.

Some key points of the new section include:

  • A new scoring system

    • Independent: Resident completes the activity by him/herself with no assistance from a helper.

    • Setup or clean-up assistance: Helper sets up or cleans up; resident completes activity. Helper assists only prior to or following the activity.

    • Supervision or touching assistance: Helper provides verbal cues or Touching/Steadying assistance as resident completes activity. Assistance may be provided throughout the activity or intermittently.

    • Partial/moderate assistance: Helper does less than half the effort. Helper lifts, holds, or supports trunk or limbs, but provides less than half the effort.

    • Substantial/maximal assistance: Helper does more than half the effort. Helper lifts or holds trunk or limbs and provides more than half the effort.

    • Dependent or helper does ALL of the effort: Resident does none of the effort to complete the activity or the assistance of two or more helpers is required for the resident to complete the activity. 

  • A new rule for how the scoring should be determined - no more rule of 3, now we will be learning to score based on “usual performance."

    • Usual performance will be assessed over a 3-day period. For admission assessments, Day 1 through Day 3 of the PPS stay. For planned discharge assessments, it's the last 3 days of the stay

    • Would reflect the typical performance of the skill being assessed

  • Assessment areas will include the following new items

    • Eating

    • Oral hygiene

    • Toileting hygiene

    • Sit to lying

    • Lying to sitting on side of bed

    • Chair/bed-to-chair transfer

    • Toilet transfer

  • Does the resident walk?
    • Walk 50 feet with two turns

    • Walk 150 feet

  • Does the resident use a wheelchair/scooter?
    • Wheel 50 feet with two turns

    • The type of wheelchair/scooter used (Manual or Motorized if the resident uses a wheelchair/scooter) to Wheel 50 feet.

    • Wheel 150 feet

    • The type of wheelchair/scooter used (manual or motorized if the resident uses a wheelchair/scooter) to Wheel 150 feet.

      Each new area will require establishing a discharge goal during the 5-day assessment


Your team is going to need time to prepare and train for the scope of changes that will be faced.  October 1 is much sooner than you think!  Below you will find a set of questions that will help you determine what you and your team are prepared for and what you still need to make decisions on to start the process.

Section GG Preparedness Questions

  • Which team member will have the responsibility for ensuring scoring accuracy and leading the process?  This discussion should include planning for:

    • Alternate leads when an individual is not available.

    • How will the team lead trigger usual performance consideration and discussion during the initial phases of the requirements to set good habits?

    • Consider morning meeting or other interdepartmental platforms as reminder times

  • Who will input be solicited from to determine usual performance?

    • What departments/ teams?

    • Will you look toward input from multiple shifts?

    • How will input be delivered and compiled?

    • How will the variations in performance levels that will occur in feedback be reconciled and given a final scoring with the new challenge of usual performance?  

  • Will you face any staffing needs to accommodate additional components?

  • How are you going to handle training?

    • Who will develop a plan for training on the new scoring system and usual performance?

    • Who will need training for the scoring system?

    • Who will be the trainer?

      • Consider having this person start the process immediately, even before final details are available, to familiarize themselves with the areas and the terminology and scoring system.

  • If your plan involves therapy playing a role in the scoring/ ownership of scoring

    • Will the process be consistent for both Rehab and Non Rehab patients? 

    • Will all therapy team members be appropriately trained to score all areas if a discipline(s) are not involved in the plan of care (the section GG will cross discipline boundaries of what typically is considered PT, OT or ST)?

  • Keep in mind that the new section GG measures will record usual performance and that you must have documentation supporting the usual performance as part of the health record. How will you ensure the level is supported?

    • Does your therapy team document daily notes for part A patients, or do they contribute to a daily interdisciplinary note in the medical record?

    • Is your team aware that the therapy evaluation and discharge summary will not satisfy to the usual performance requirement and should not be considered the scoring tool of record as both are "snap shot" assessments and do not meet "usual performance" standards?

Practice makes perfect

As you work, and likely rework, through the questions above, consider having your interdisciplinary team start practicing the usual performance scoring as well as discussing outcomes goals for patients. This can be done informally to start, perhaps during morning meetings or weekly q/a meetings for recent admissions.  

As time grows near for the actual implementation, consider having a more formal trial of your process. I recommend you trial for minimally one month, longer if you do not have a high volume of admissions, to allow for identifying any flaws in your planning and to allow all team members to gain a comfort level with the new regulation.

Planning and preparation now will prevent anxiety and risk of inaccurate reporting (and the consequences that can bring) starting October 1.


Kim Lewis is the VP of Clinical Advancement & Data Integration for TMC, which provides contract therapy services in SNF, CCRC and Assisted Living centers in the Southeast and throughout the US. She 
oversees system creation, content and user interface for the company's proprietary documentation and billing software. 


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