The Centers for Medicare & Medicaid Services has clarified steps providers must take to comply with Minimum Data Set requirements regarding incomplete or unsubmitted discharge assessments.

Skilled nursing facilities and nursing facilities are facing an approaching deadline on this issue, as MDS assessments older than three years will not be accepted as of Oct. 1.

By Sept. 30, facilities should identify any inactive residents who are still appearing on the current MDS 3.0 roster report, according to the CMS memo issued Friday. To deal with these incomplete or unsubmitted discharge assessments, providers should take different steps depending on whether the discharge date was before or after Oct. 1, 2012. For example, clinical information in sections B through Z should be “dash-filled” for residents discharged prior to Oct. 1, but these sections should be completed “as much as possible” for residents discharged after that date.

“The failure to submit or complete MDS 3.0 discharge assessment records leads to inaccurate MDS 3.0 Quality Measures (QMs) data, potentially affecting the resident, the facility’s payment and facility liabilities,” the memo states. “For example, failure to submit or complete MDS 3.0 discharge assessment records can also lead to citation of a facility under 42 CFR §483.20(f) and 42 CFR §483.20(g).”

Many skilled nursing facilities are not meeting discharge planning requirements, such as creating summaries of a resident’s stay and status at discharge, according to a government report issued in February.

Click here to access the complete Aug. 23 memo.