Michael Katri

We all know Section GG is coming – but are you ready?

Preparing for this mandate now will give you time to navigate the required data and provide adequate training for your staff. Then, on October 1, you will have peace of mind knowing you’re compliant. Keep reading to identify the major requirements contained in Section GG and get tips for creating a successful implementation plan.

Before you can start the countdown, it’s important to understand the basic implications of Section GG.

  • What it is: Section GG is a new section of the MDS that becomes required for SNF PPS patients on October 1, 2016.

  • Where it came from: The IMPACT Act of 2014 called for the regulation of quality measures via a standard assessment tool, with the goal of improving patient care and creating connections across the post-acute care continuum. The Centers for Medicare & Medicaid Services responded by leveraging the CARE Item Set, which measures functional items including mobility and self-care. Section GG includes some of the required CARE Item Set assessment items, and includes a discharge goal reporting requirement, and additional patient information requirements.

  • What it means for your business: Data reported on the Section GG self-care and mobility items must reflect a patient’s usual performance in the specified assessment time period. Since Section GG is a SNF provider requirement, whether your therapists collect the data to assist in defining each SNF-PPS patient’s usual performance is a matter of organizational preference.

Regardless of what you decide, be sure to check with your software vendor to make sure they will offer configuration options that allow the therapy team and/or non-therapy facility staff to collect the data, so you can tailor the system requirements and associated prompting to your workflow.

Additionally, many SNF therapy providers have been collecting CARE Item Set Mobility and Self-Care assessment data on their patients over recent years. The Section GG set of items has some variances when compared to the CARE Item Set quality measure. For these providers, integrating the collection of Section GG data and CARE Item Set quality measure data should be a high priority in order to maintain operational efficiency and consistency of assessment data.  Ask your software vendor about their plans to support this integration.

If you choose to have your therapy staff be responsible for the Section GG self-care and mobility assessments, the next step is to create a timeline with milestones leading up to the October 1st deadline.

  • May 2016: You should have already received communications from your software vendor regarding Section GG and enhancements being made to support the mandate.

  • June – July 2016: Now is the ideal time for education and training. Ask if your software vendor offers regulatory consultative services; these are well worth the investment when it comes to important mandates like Section GG.

  • August – September 2016: Your software vendor should have completed all development work to support Section GG by mid-August, which means you’ll have at least a month to become familiar with the enhanced functionality.

  • October 1, 2016: Section GG is officially required on PPS 5-day and Discharge assessments.

After you have a working timeline, the focus should switch to education. Ideally, your therapists will be fully trained by August – September 2016 so they are ready to use and test Section GG functionality when your software vendor releases it, prior to the October 1 deadline.

With an established operations and education plan, you will empower your organization to not only comply with Section GG, but to do so with confidence.

Michael Katri is the chief product officer at Optima, which he joined in 1998. Click here to access a recording of Optima’s Regulatory Webinar: How to Prepare for Section GG and the Mandatory CARE Item Set Changes.