Ask the payment expert: What is the impact of Section I of the new MDS 3.0?
Ask the payment expert
New MDS 3.0 guidelines could change facility processes. The RAI Manual states that this section of the MDS has two “look-back” periods. Step 1 is Diagnosis identification and is a 60-day look-back period. This means that it requires a physician-documented diagnosis in the last 60 days. (A nurse practitioner, physician assistant, or clinical nurse specialist also could document if allowable under state licensure laws.)Step 2 is Diagnosis Status: Active or Inactive, and is a seven-day look-back period (except for Item I2300 UTI, which does not use the active seven-day look-back period).
The challenge in many facilities will be Step 1. Many facilities have diagnoses identified on the admission orders and may have a diagnosis list that is kept up-to-date in the medical record. Those facilities that do have diagnoses on the physician order sheets do not always update those diagnoses. It will now be essential to make sure those diagnoses are current and signed by the physician every 60 days.Active diagnoses mean that they have a direct relationship to the resident's functional status, cognitive status, mood or behavior, medical treatments, nursing monitoring, or risk of death during the seven-day look-back period.
This section also could become a reimbursement risk area and may become very important for medical review or RACs reviews. CMS states that if the facility is using a V-Code (treatment) diagnosis, a supportive diagnosis also must be identified.This information could be used to verify whether services rendered to the resident were appropriate for the condition of the resident. The lack of this support is a critical issue that is being identified in medical review activity across the country.