What does MDS item Z0400 have to do with supporting cognitive impairment for PDPM?
Under the Patient Driven Payment Model, cognitive level is identified through completion of the Brief Interview for Mental Status (BIMS) or the Staff Assessment for Mental Status.
If the interview or assessment indicates the individual is cognitively impaired, the speech-language portion of the PDPM daily rate is increased. What documentation, if any, is needed to support this information on the MDS? You may be thinking that the interview stands alone, and you’d be right — to an extent. The interview sections of the MDS don’t require additional supporting documentation because answers are provided directly by the resident. What is necessary, however, is evidence that the interview was conducted according to the Resident Assessment Instrument (RAI) requirements. The interview should be conducted within the look-back period, preferably the day before or the day of the Assessment Reference Date (ARD); This is where Z0400 comes in. Z0400 provides the signatures of persons completing the assessment and also houses the date a specific MDS section is completed.
If the BIMS is signed as complete at Z0400 on a date after the ARD, reviewers will likely invalidate the interview, score the BIMS as 15 to indicate normal cognition, and recalculate the SLP component. You may be able to rebut this type of overpayment audit finding by presenting alternative documentation, but every attempt should be made to enter interview data into the MDS on the day of collection.
The RAI also provides the following guidance: If a staff member cannot sign Z0400 on the same day that he or she completed a section, when the staff member signs, use the date the item was completed.