Rajeev Kumar, M.D.

Fall is here, and football season has returned with much fanfare — quite like the eagerly anticipated arrival of the Patient-Driven Payment Model.

Unless skilled nursing Interdisciplinary teams practice good clock management, huddle up often and catch missing information to ensure they beat the clock with a 100% MDS completion percentage, facilities won’t advance from the red zone to the end zone.

Too many football analogies? Sometimes the fan in me just takes over. Sorry, but I ain’t apologizing! It is hardly unsportsmanlike conduct.

After a football game is done, it is easy for us to look back at what actually transpired, second-guess what could have, and should have, happened, and then envision an altogether different result, if only our team had approached certain plays differently. 

Thankfully, we have the opportunity to be Monday morning quarterbacks and ensure we are every ‘quarter back’ to our SNFs by making use of 7-day lookbacks under MDS. 

Medicare is aware of the challenges, and complexity, of timely MDS completions, especially in the context of PDPM. Forty-plus pages of electronic documentation, covering 168 fields in MDS, need to be accurately completed on time by SNFs, for each resident under their care, to be fairly reimbursed for services and care rendered under the new model.

The Initial MDS Assessment is the prime driver of reimbursement for the entire duration of a resident’s Medicare A stay, unless an Interim Payment Assessment (IPA) is performed.

Even as Medicare allows SNFs to complete Initial MDS Assessments in 8 days, there is a built in 7-day lookback period that captures patient characteristics and services rendered to be documented on the Assessment Reference Date. That happens even if those characteristics and services have changed or evolved during the lookback period.

While most patient characteristics and services can be captured only from the time of admission, there are some that can be captured from the preceding hospital stay — as long as the initial assessment is performed early enough, so that the look back period extends into the hospital stay. Talk about hidden yardage!

Patients are generally sicker while in the hospitals and receive a comparatively higher acuity of care in that setting. Capturing the higher utilization of resources from that setting is bound to improve the case mix for SNF patients, and therefore, is an important reason to complete Initial MDS Assessments as soon as possible.

Speech Therapy, Non-Therapy Ancillaries (NTA) and Nursing categories will likely experience the most improvement. Examples of such finds through a lookback into the hospital stay would include total parenteral nutrition (TPN), tube feeds and oxygen administration. Section K0500 on MDS allows a 7-day lookback at patients receiving parenteral/intravenous hydration/nutrition during a nursing home or hospital stay, as outpatient or inpatient, provided they were administered for nutrition or hydration.

The 7-day look back can truly be a SNF team’s much-needed time out to rehash, and score extra points. CMS generously allows us to time travel, review and pick scoring plays in this fantasy league known as PDPM. However, there are no opportunities for a coach’s challenge, as red flags have been replaced by white ones. Throw them at your own peril, for there’s no safety in that thought.

“Hey,” you might wonder, “whatever happened to fair play?”