Joel VanEaton

The PDPM RAI Manual is here, Now what?

We’ve had a little over a month to process the RAI manual, but there’s no denying that this year is different.

Generally, the RAI Manual details the changes for the upcoming year and there is a flurry of organizations and individuals who offer their take on the details through various informational and training modalities. Everyone settles into the updates and life goes on. It is a bit of an annual rite of passage for those in LTC who live by the words of the RAI Manual.

But this year, we are on the cusp of most extensive revision to a post-acute care payment system since the implementation of PPS in 1998. We have gotten used to the current RUGs based system, with relatively minor variations (44, 53, 66), for the last 21 years. That’s a long time, and habits that have been formed over that period of time are well established.

These habits, as “comforting” as they may be, will have to be discarded. This year the RAI Manual must be embraced with a fervor that may not have been felt since MDS 3.0 was introduced nine years ago.

The first version of the RAI Manual, v1.17, that will take effect this October may be accessed here in the “Related Links” section at the bottom of the page. If you have not downloaded it, it would be a good idea to do so. CMS has organized it so that, other than Chapter 2, revisions have been highlighted in the change documents as they have in the past as well red lettering the actual text of the document. CMS has also done a great job at providing educational resources about the revision during the QRP training provided in Kansas City earlier this month. The relevant training documents may be found here in Day 1 Part 1. 

The only portions of the manual that have no highlights or red-letter text are Chapter 2 and 6. In the associated change document for these chapters CMS indicates, “This chapter has been extensively revised for this year’s manual. Due to the scope of the revisions, individual changes have not been recorded and tracked in this Change Table. Users are encouraged to review the chapter in its entirety.” Having read these chapters, I concur.

The majority of the revisions to be found in this first release of the RAI Manual have to do with the PDPM. The takeaway is that in order to be sure that you understand the new payment system with all of its policy changes, particularly as they apply to the MDS, downloading and becoming familiar with the revised sections is a must. And I mean it is a must! CMS has gone to great lengths to further explain what has, up until the RAI Manual posting, only been available on the PDPM website. Understanding these revisions without the context of the RAI Manual is only half of the story. CMS has given us a significant lead time to prepare with this posting. 

Be forewarned though, this will not be the last version that will be released before October 1. There may also be further clarification to other PDPM related items based on stakeholder feedback in response to the proposed rule and the continuing accumulation of Q&A that CMS is facilitating.

The material that CMS will provide to the provider community to assist in preparing for the implementation of PDPM continues to grow. The RAI Manual is just another, but a very important “another”, that should be treated as venerable as knowing the details of PDPM have been and will continue to be. 

Henry David Thoreau once said, “I went to the woods because I wished to live deliberately, to front only the essential facts of life, and see if I could not learn what it had to teach, and not, when I came to die, discover that I had not lived… I wanted to live deep and suck out all the marrow of life, to live so sturdily and Spartan-like as to put to rout all that was not life…”

It seems to me that it is not hyperbole to suggest that transition to PDPM will require this type of fortitude and resolve, part of which will require that providers become intimate with the revised RAI Manual.

Joel VanEaton, BSN, RN, RAC-CT is the VP of Compliance and Regulatory Affairs at Broad River Rehab.