Joel VanEaton

Do you like playing cards? I do. I find it enjoyable to gather friends together for an evening of card playing. I would be lying if I didn’t say that there was no competition involved. Mostly though, it is just a relaxing time to reconnect and enjoy each other’s company.

We will all be enjoying each other’s company a great deal over the next year as we work together acclimating to the new MDS 3.0 v1.18.11. So many things will change relative to the revisions the Centers for Medicare & Medicaid Services has made to this item set. In many ways, it feels like it should be called “MDS 4.0.”

The majority of the revisions that have been made to the revised MDS have to do with what are called Standardized Patient Assessment Elements or SPADEs. It’s a new “game” we will all learn together before October 2023.

SPADEs is not a new concept. One of the mandates of the IMPACT act “… requires the submission of standardized data by Long-Term Care Hospitals (LTCHs), Skilled Nursing Facilities (SNFs), Home Health Agencies (HHAs) and Inpatient Rehabilitation Facilities (IRFs). Standardized data are to be collected by the commonly used assessment instruments…”. 

Ever since the IMPACT act was signed into law in 2014 and the resulting Quality Reporting Program (QRP) began, post-acute data sets have been adapting to the use of SPADEs.

CMS’ expectation is that the use of these data elements will provide a level of interoperability among post-acute care settings not possible before and to improve Medicare beneficiary outcomes. The SPADE data collected by each care setting is intended to allow the same language to be spoken relative to a beneficiary’s care needs addressed by the SPADEs. 

In MDS 3.0 v1.18.11, CMS is adopting SPADEs for five categories specified in the IMPACT Act:

  • Cognitive function 
  • Special services, treatments, and interventions 
  • Medical conditions and comorbidities 
  • Impairments 
  • Social Determinants of Health

Now, the task is to learn the rules. I am a stickler for rules. When we play cards of other board games at my house, the rules are central to ensuring fair play. I am constantly referring to the rules throughout the game to ensure the game is played correctly, much to the annoyance of some of my friends. We’re still friends, though. 

Coming soon

In a recent Open Door Forum, CMS was not very specific as to when the “rule book” would be available. The RAI Manual will be published next year sometime. However, they were able to tell us that all of the data sets are expected to be released before the end of the year and that is some helpful news. 

With the elimination of most of section G in MDS 3.0 v1.18.11, though, the residual effect of that change on the CAAs, QMs, Five-Star ratings and STRIVE data that affects the acuity adjustment for the Five-Star staffing measures, will be significant. CMS indicated that learning resources relative to these changes would be forthcoming but could not be specific as to when.

All this to say that we have some learning to do. For the time being there are some resources, or “rules,” available to start that process. 

In the summer of 2019 CMS released the Final Specifications for SNF QRP Quality Measures and Standardized Patient Assessment Data Elements (SPADEs). This is a helpful tool to understand more specifically about the SAPDEs. 

Recently, CMS also released the FY 2025 SNF QRP Table Reporting Assessments Based Measures and Standardized Patient Assessment Data Elements document. This is a document that details the items on the MDS data set that are used to calculate reporting compliance for the Annual Payment Update (APU) adjustment. 

The process begins in earnest

SNFs are required to report 100% of the MDS items necessary to calculate the SNF QRP quality measures on at least 80% of MDS assessments. If that threshold is not met, SNFs will lose 2% of their annual market basket update. If that were to apply to FY 2023, instead of a 5.1% rate increase, noncompliant facilities would receive only 3.1%. That leaves very little when the 2.3% parity adjustment is applied. 

You will note that for FY 2025 the data elements that will be included in this threshold has grown significantly to include all of the SPADEs included in MDS 3.0 v1.18.11. The rules have changed!

I’m in this with you. I am looking forward to learning the rules, as they become available, and applying them to this new game of SPADEs. 

I heard a great “Dad” joke the other day. Do you want to hear it? 

“Did you know that milk is the fastest liquid on earth? It’s pasteurized before you even see it.”

Don’t let the MDS 3.0 v1.18.11 rules that are slowly being released get past your eyes. The new game of SPADEs will be here before you know it. The cards are on the table … How will you play your hand?

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.

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.