Q: What is the impact of Section G being removed from the MDS?

A: As you may have heard, the Centers for Medicare & Medicaid Services released the draft Minimum Data Set Nursing Home Comprehensive Item set version 1.18.11 on Sept. 1. Among many other changes, Section G was notably absent.

You may recall substantive changes were originally planned for 2020 but were pushed back due to the public health emergency and stakeholder concerns. Now, CMS is preparing to move forward with implementation starting Oct. 1, 2023.

On one hand, the removal of Section G is welcomed as coding of the section has been confusing since its inception. On the other hand, what does this mean for other processes that rely on Section G data?

Medicaid payment — Several states rely on an ADL score calculated from Section G that is used, in part, to establish RUG scores that inform reimbursement. These states will need to hasten planning for a new approach, whether that is a PDPM-version for reimbursement or a requirement for completion of the Optional State Assessment.

Quality Measures — Some Section G items are used as part of QM calculations directly or via covariates or exclusions. A major overhaul will be needed.

Care Area Assessments — As part of the care planning process, Section V of the MDS houses the CAAs, some of which are informed by coding responses in Section G. This, too, will need to be revised as to what “triggers” applicable CAAs.

While there is a year before implementation, you should start preparing now. Review the draft item set for all changes — there are many besides Section G — and keep watch for the release of new information, including the revised RAI and QM manuals. As this is a draft, additional changes could still be made.

Eleisha Wiles, RN, RAC-CTA, RAC-CT, DNS-CT, is a clinical consultant at Proactive Medical Review. Send her your payment-related questions at [email protected].