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MDS Frequently Asked Questions

Nursing Homes

Question: If a facility has not been doing an entry tracking on residents since the MDS 3.0 came out, how far back should the facility go to correct this problem?

Answer: CMS set December 1, 2010 for the date facilities will have to go back to and correct all the tracking forms that were not completed for all residents in the nursing home.

Question: A resident that comes in SNF with payer source being a HMO paid by levels.  Only OBRA assessments are required for re-imbursement.  Four (4) months later, it is learned the payer source is actually traditional Medicare.  Is it okay to open a 14-day within the original 14-day window and complete the assessment for payment?

Answer: No, you cannot open a PPS 14 day assessment 4 months later when one was not completed.  Read the MDS 3.0 manual on page 6-53 for Missed Assessment regarding billing the default rate.  You can also contact the Fiscal Intermediary for your area and determine how they would suggest that you bill for default days because it is too far after the fact to do an MDS assessment now for what occurred 4 months ago.  As the MDS manual says, you may be able to use an OBRA assessment RUG value to bill.

Question: In the October update to the RAI manual under section I, the directions had a sentence added regarding "new normal."  The manual does not provide any information on how to determine what is to be considered the new normal.  Could you please provide guidance on how to determine what "new normal" would be.?

Answer: In Section I of the MDS 3.0 manual on page I-3, the term “new normal” is used to describe a diagnosis/condition that has been resolved but that the person still has residual symptoms from that original diagnosis and the symptoms are not new and/or related to a new diagnosis in the past 60 days but has become the person’s new normal or new baseline since the original diagnosis of months or years ago and is no longer relevant to describe a new diagnosis.  CMS is reviewing and considering revisions for Section I, for the next manual update. 

Question: In section O, physician orders and physician examination could not be an employee of the facility.  No guidance was provided as to what was defined as employee of the facility.  Could you please provide guidance on what is considered as employee of the facility in this case?

Answer:  Under Coding Tips for the Physician Examinations and Physician Orders in O0600 and O0700, the examinations and orders cannot be completed by physician extenders that are employees of the nursing home; they can only be working in collaboration with the physician. The definition of employees of a nursing home means that the person is employed by the nursing home.  This pertains to physician extenders who are not working in collaboration with a physician and are employed by the nursing home.  Federal Regulations at F 390 of Appendix PP of the SOM provides guidance as to what is considered an employee. S&C Letter 03-18 also explains more in detail.  In regard to these Items in Section O, CMS is reviewing and considering revisions for the next manual update.

Swing Bed Facilities

Question:  A patient that was admitted to swing bed rehab on Friday and discharged on Monday.  The patient received the therapy evaluation and one session on Saturday.  We completed an entry tracking form.  The patient was not in the facility long enough to complete the interviews and capture enough information for a 5-day assessment.  Our interpretation of the manual... she does not qualify for a short stay either...  What is the best way this situation should be handled?

Answer: You will do the Entry Record and submit separately.  Then you can do the Medicare PPS 5 day and the Discharge Assessment combined and submit.  The nursing  home will not be paid for the day of discharge because the resident was not in bed at Midnight on that day, but therapy can bill Medicare for services that they provided and you will need the Medicare PPS 5 day for that billing.

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