As most long-term care operators can attest, MDS 3.0 has spurred both opportunities and obstacles. On one hand, the new resident assessment tool is pushing resident care and satisfaction to the forefront – a notable plus for any quality-focused operator. On the other hand, operators are finding the new requirements even more laborious and complicated, two critical factors that can increase the risk for error on MDS submissions and, subsequently, lead to increased citations, reduced reimbursement and lower quality scores.
Without question, data integrity plays a vital role in a facility’s MDS success – or failure. Having a data integrity tool that effectively analyzes the data and proactively pinpoints potential holes, inconsistencies or inaccuracies affords an opportunity to correct those errors before the MDS is submitted to the Centers for Medicare & Medicaid Services. What some operators may not recognize, however, is that all data integrity tools are not created equal. In fact, a recent study by PointRight Inc. led to an eye-opening discovery: The overwhelming majority of assessments that undergo data checking by Electronic Health Record/MDS software systems is inaccurate.
“We found that 90 percent of assessments that underwent so-called data integrity checks by EHR systems have more than one error – 2.33 errors, on average, to be exact,” said Steven Littlehale, EVP and chief clinical officer at PointRight Inc. “Operators believe that data integrity is good because it went through an MDS or EHR system’s data checker and that just is not accurate.”
MDS data errors can prove costly to a long-term care operator. Not only might an error or oversight lead to under-coding and subsequent reduced reimbursement – an all too common outcome, experts say, despite government claims to the contrary – data errors or unsubstantiated exceptions on the MDS also may lead to unintentional overpayment and subsequent RAC or MIC audits.
“Even if it’s determined that an exception can be [substantiated] and money won’t have to be paid back, facilities will still waste a lot of time and resources gathering the data and documentation needed for the audit,” explained Leon E. “Ed” LeBreton, CEO of The Lancaster Group LLC, a Lancaster, PA-based firm that assists operators in the preparation of Medicare and various state Medicaid cost reports.
Because RAC and MIC auditors review exception reports to determine which facilities and assessments to audit, LeBreton explained that operators with good data integrity tools can not only significantly reduce their time spent reviewing MDS assessments, but also identify and address potential exceptions, coding errors and documentation gaps before submitting an assessment to CMS.
“Having these tools available and being able to be proactive on the front end can prevent a lot of problems on the back end,” he said.
Attention to detail
Given the amount of data that goes into each MDS assessment – not to mention, the sheer volume of assessments operators must submit each month — it stands to reason why a powerful and comprehensive data integrity audit tool is so essential.
PointRight’s Data Integrity Audit is just that, applying more than 300 clinical and logical tests, and in addition, the CMS coding and consistency checks, to every MDS assessment. These powerful checks give users the confidence that their assessments are accurate, along with the opportunity to view each assessment the same way a surveyor, RAC or MIC auditor, or plaintiff attorney would. Data Integrity Audit (DIA) users then get immediate online feedback on potential inconsistencies and documentation requirements to allow prompt, proactive resolution.
“Having accurate data has always been important, and it’s incredibly important now because any inaccuracies which aren’t caught or addressed will soon be released to the public,” said Jennifer Gross, RN, BSN, BA, senior healthcare specialist for PointRight. “If you know what’s going on in your data, you’ll have the opportunity to jump right in and make the improvements now instead of having your dirty laundry aired in public later.”
Case mix master
The heart of DIA’s power and value lies in its ability to drive accurate RUG/case mix reimbursement, improve quality measures and compliance with regulations, policies and procedures, and reduce risks, fines, deficiencies, and audits. As Littlehale explained, data inconsistencies are not only identified by DIA, but explained, and users are even prompted when and where additional documentation or clarifications may be needed in the assessment. Beyond that, DIA’s online reports show the proper coding source, including where the coding guidelines may be found in the RAI manual. DIA also aggregates performance data, shows improvement from first to final MDS submission, clearly illustrates performance by each MDS section, and provides resident-level drill-down of clinical and reimbursement-related data integrity issues.
Even more importantly, though, having a powerful, reliable data integrity auditing tool like DIA spurs quality of care improvements and promotes best practices through ongoing training, improved interdisciplinary care process development and organization-wide benchmarking.
“One of my greatest assets at the corporate level is having the ability to monitor data being submitted and then look at trend comparisons across our different facilities,” said Joyce Nicholson, RN-BC, RAC-CT, MDS process and reimbursement manager for the Franciscan Sisters of Chicago. She pointed out that while data integrity is essential for ensuring accuracy of MDS submissions, the same can be said of DIA’s ability to give Franciscan Sisters of Chicago a clearer picture of processes and practices, while highlighting areas in need of improvement at the organization level and within each of its ten facilities.
Clinical helper
Having that ready access to clinical data and reports through PointRight’s DIA has not only benefited MDS coordinators, but also wound care nurses and other clinicians who have used the data to improve documentation and turn an even sharper eye on resident care processes and delivery, according to Nicholson.
“DIA gives me the flexibility to look at our data in a number of ways – being able to get that big picture from a corporate level and then also drill down by state and individual community,” she said. “The more information you have and the more reliable that information is, the better able you are to make informed decisions and positive changes that impact resident care. And that’s the most important benefit of any tool.”
