Have you ever read a really good book that was subsequently made into a movie? I have. Time after time, after watching the movie, I end up walking away thinking, “I wish I had just stuck with the book… again.”
As we face MDS 3.0 v1.18.11 implementation this October, there have been a slew of resources made available to SNFs to begin preparations for this change. They are worth taking advantage of. As I have said many times, v1.18.11 of MDS 3.0 feels more like MDS v4.0 to me.
Here is what is available so far.
- In February, the Centers for Medicare & Medicaid Services released the DRAFT technical specifications.
- In April, CMS released the final MDS data set, CAT specifications and the DRAFT RAI Manual.
- In May, CMS has posted a series of virtual training sessions on YouTube that detail the upcoming changes and
- On June 21, CMS will provide a half-day live virtual event that will augment the YouTube videos.
The movies have been released. Have you watched the YouTube training videos yet? You should. There are 11 videos. You’ll need to prepare to spend about four hours of your time viewing all 11.
It will be time well spent. In my opinion, CMS did a pretty good job of producing these training vignettes.
Video 11 begins the process with an overview of the changes. The remaining videos, all the way through video one, spend significant time detailing the changes for a well-rounded engagement.
There are a variety of revisions throughout the manual. Most of the substantive revisions and changes are related to implementation of the mandates from the Improving Medicare Post Acute Care Transformation Act, or IMPACT Act.
This legislation signed in 2014 has had and will continue to have significant impact on quality reporting and Standardized Patient Assessment Data Elements (SPADEs).
The core 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).
It requires assessment data to be standardized and interoperable in order to allow for exchange of the data among these post-acute providers and other providers.
Ultimately the intent is for standardized post-acute care data to improve Medicare beneficiary outcomes through shared decision making, care coordination, and enhanced discharge planning.
That seems like a tall order. But it’s happening, and MDS 3.0 v1.18.11 is taking these mandates to the next level for SNFs. The primary changes to the MDS and RAI Manual are related to the IMPACT ACT mandates. Accuracy is key and that’s where the training videos come in.
It’s also key to understand the reporting requirements for these data elements and the incentive for reporting them.
Currently, facilities must report 100% of the MDS data elements that are used to calculate the SNF QRP Quality Measures on at least 80% of the MDS assessments submitted to IQIES or they will lose 2% of the annual payment update (APU), or Market Basket Update.
SNFs must also report 100% of the data for COVID and Influenza vaccination to NHSN or risk the same penalty, a conversation for another day. The point is, both standards must be met.
MDS items that are required to be reported are listed in the SNF QRP Table for RABM for the FY 2024 SNF QRP APU and the FY 2025 SNF QRP APU Table for Reporting Assessment Based Measures and Standardized Patient Assessment Data Elements.
Note that SPADEs have been added to the FY 2025 document title. When you download these two documents, you will notice that the data elements that will be required to be reported for FY 2025 APU adjustments have increased significantly compared to FY 2024. That’s due to the IMPACT Act and the standardized data elements that have been added to MDS 3.0 v1.18.11.
It is also important to take note of the fact that in the FY 2024 SNF PPS proposed rule that was released back in April, CMS has proposed to increase the MDS based data elements reporting requirement.
If finalized, the reporting requirement will be 100% of the data necessary to calculate the assessment based SNF QRP measures and 100% of the SPADE data elements on at least 90% of the MDS assessments submitted to IQIES.
That’s a high bar for so many MDS data elements. CMS is serious about standardized data reporting and the IMPACT act requirements.
The changes coming our way this fall are substantial, from the data reporting requirements to the paradigm shift to health equity and social determinants of health, but that’s another conversation for another day. It’s like an action movie that keeps you on your toes until the very end.
We still don’t know how the quality measures that are currently driven by section G will be affected by the upcoming changes. That information has been promised by CMS for some time after October 1. Perhaps a sequel of training videos is in the works.
At any rate, the training that has been provided so far is pretty good. I have noted in some of my trainings on the upcoming changes that, in preparation, we should be reading the RAI Manual like we are reading it for the very first time.
After watching CMS’ MDS 3.0 v1.18.11 training videos, I still believe we should do that. But, having viewed all 11 videos, I’m inclined to say that the movie, while not the RAI manual, at least makes the book worth reading.
That’s more than I can usually say about a movie that’s made about a book. Let’s get learning!
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.
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