Skilled nursing facilities across the country unknowingly entered an escape room on Oct. 1, searching for a unique combination of clues, keys and passcodes to solve the puzzle. 

Their mission: Performing routine completion and submission using the new Minimum Data Set (MDS) 3.0 assessment version 1.18.11. 

The challenge: electronic medical record (EMR) software vendor glitches. With every click of an MDS, providers were unsure. Had they selected the right combination to unlock and proceed, or would they reach another locked door? The sheer volume of EMR errors made an already challenging transition exponentially more difficult for SNFs to navigate.

Providers were left with a difficult decision: to delay their MDS submission until system edits were issued or to submit MDSs with incorrect codes. During a Centers for Medicare & Medicaid Services Open Door Forum on Oct. 12, when questioned by callers, officials discussed the ramifications of not submitting an MDS: claims submitted without an MDS submission will not be paid. 

CMS officials were unable to provide specific remedies for software errors, or estimated timelines for correction, instead directing providers to work directly with their vendors, Medicare Administrative Contractors (MACs), or contact the Internet Quality Improvement & Evaluation System (iQIES) help desk.

EMR errors were not specific to any one vendor; CMS said all EMR vendors experienced problems. To illustrate the magnitude and complexity of errors providers encountered, one-month post-implementation of the MDS 3.0 version 1.18.11, one of the most prominent EMR software in the U.S. continues to investigate unresolved errors, releasing a multi-page document detailing the status of resolutions. 

So what’s going on? Across multiple software vendors, providers reported significant complications:

  • Health Insurance Prospective Payment System (HIPPS) scores were not calculating for OBRA assessments 
  • Incorrect HIPPS scores were calculated for MDS assessments for Medicare 
  • Erroneous skip patterns resulting from both CMS technical errors and EMR technical errors
  • Not able to obtain Resource Utilization Groups (RUGs) scores
  • Received inaccurate Patient Driven Payment Model (PDPM) scores
  • Section GG calculation errors
  • Unable to submit MDS assessments
  • Software patches were issued after the fact, and are not consistently updated

What can providers do? Prepare for intensive Triple Check meetings. These meetings will be both critically important and technically challenging. 

The Triple Check process ensures billing accuracy and conformance with regulatory requirements prior to the submission of claims for payment and involves interdisciplinary team (IDT) review of admissions, billing, and MDS for Medicare/Managed Care residents. 

Typically, IDT members use reports created by their EMR to guide Triple Check. With the current situation surrounding EMR errors post- MDS v 1.18.11 implementation, these reports should be considered unreliable. 

SNF IDT members participating in a Triple Check meeting should use their acute understanding of how each case mix adjusted component under PDPM – Physical Therapy (PT), Occupational Therapy (OT), Speech-Language Pathology (SLP), Non-Therapy Ancillary (NTA), and Nursing – is calculated, to verify accuracy of claims for payment. Moreover, SNF IDTs will need to recognize errors caused by both EMR glitches and human error. 

The MDS 3.0 version 1.18.11 included significant changes to the MDS process impacting documentation sourced from multiple disciplines, creating the perfect environment for additional errors caused by misinterpretation of MDS changes.  

Providers should plan to suspend use of EMR reports for Triple Check meetings for October 2023 and November 2023 claims. 

Three tips for Triple Check meetings

  • For MDS’s completed before Oct. 1, download prior period reports from EMR software. Unless a new Interim Payment Assessment (IPA) MDS was completed, providers can use prior period reports to verify that the HIPPS score or Patient Driven Payment Model (PDPM) score remains the same. 
  • For MDS assessments completed on or after Oct. 1, confirm the accuracy of each case mix group.
  • SNFs located in states approaching a case mix freeze should review and optimize Medicaid case mix index (CMI) scores; determine if any residents need an MDS completed prior to the cutoff date.

Maureen McCarthy,  RN, BS, RAC-MT, QCP-MT, DNS-MT, RAC-MTA, is the President and CEO of Celtic Consulting, a post-acute advisory firm which provides assistance to skilled nursing providers across the nation.

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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