CMS Updates on Hold: 5 Things You Can Do Now to Stay Ready for the Changes
- Vanessa Tyscka, RN, BSN, MBA, RAC-CT
- Sep 28, 2021
- 4 min read
Photo by Chris Lawton on Unsplash
In our world of constant change and chaos, healthcare workers and operators are hard-pressed to get a handle on staffing let alone manage all the other demands of operating a successful SNF. One thing is always certain though, it is much easier to plan ahead than trying to play catch-up. Although CMS has delayed many of their usual annual changes for FY2022, there are a few things that can be done in the MDS world to ensure you land in a good place when CMS begins the 'unfreezing process'.
If you can, utilize your technology to project what you should focus on. CMS has dropped a few clues regarding the bullet points below since the implementation of PDPM. Furthermore, they believe they have been overpaying us as evidenced by the proposed payment decreases they have (at least for now) temporarily. If your facility provides a scrubber, you should be able to pull reports to look at most of the following items. If you don't have access to such reports some chart audits can reveal areas that need to be focused on.
Extensive Services - The rise in Extensive Services might just be a blip due to the COVID-19 pandemic, but it will serve your facility well to ensure that the beneficiaries who were coded for isolation actually met ALL four criteria. This area has always been a red flag for surveyors as it is an often miscoded question. If isolation was ordered for COVID-19, ensure that you have an actual diagnosis (not suspected or exposure to). Also, ensure that the documentation noted activities, nursing and therapy indicate that treatments were brought to and completed in the residents room.
Skilled Nursing Documentation - The requirements for documenting skilled necessity have not changed, however, CMS has doubled down on the importance of it under PDPM. In fact, it has become even more magnified during the pandemic and use of the 1115 Waiver to skill in place.. Help the floor nurses understand which areas of their patients plan of care are are skillable and guide them to document on these items. Teach them to document what they [the nurse] did for their patients and how the patients responded. Don't forget to get the certification and documentation of skilled necessity signed by the physician.
Diagnoses and NTAs - Since so many diagnoses affect reimbursement, be sure you have met the requirements to code them. This may seem simple, but many diagnoses and NTAs are miscoded because of lack of physician documentation or they are not active. If your facility has shown an increase in NTA points over the course of the last year or so make certain there is documentation indicating active diagnoses and documentation from the physician or extenders.
SLP - Make sure you have good communication with your SLP. This is an important case-mix area that can easily be missed. Ensure that they know to document any observations regarding swallowing status and cognitive deficits. Of course, always review their evaluations and treatment notes. PT/OT no longer impact payment rates, but CMS said they will be monitoring these programs as well. In particular they want to ensure facilities are not cutting therapy treatment in lieu of saving dollars. Continue to review therapy documentation and ADLs to ensure we are giving residents the treatment they need.
Depression - If your facility has seen an uprise in Depression scores, ensure that you have good documentation to support the increase in severity of their symptoms. Ensure that you have good interventions in place and that the MD is aware of any changes. And of course create a strong, resident-centered care plan! If you have residents that have dementia or cognitive impairment don't forget they must be interviewed as well - if they refuse or aren't understood document that the interview was attempted and any pertinent details regarding the attempt. This is a requirement! A couple of other coding tips: If an interpreter is needed but not available, answer “no” to C0100 but DO the staff assessment. If the interview was not attempted but should have been, code "yes" to C0100 and dash the interview items, DON'T complete the staff assessment.
Taking some time this fall to ensure your MDS coding is airtight will serve you well for the future of PDPM and QAPI. Remember that some of the QRP and QM items that will be updated at the beginning of 2022 year have already been coded, submitted and data collection is occurring now!
MDS Solutions HQ Do you want to take your facility to the next level? Let MDS Solutions HQ show you where your opportunities are. Whether it’s improved quality of care, better survey outcomes or if revenue is your focus it all begins with the MDS. I specialize in training MDS nurses in the RAI process, training floor nurses to document skilled need, educating revenue capture through the PDPM process, analyzing and creating action plans for QM and 5 star success.
Contact me at:
MDSSolutionsHQ@gmail.com or 404-309-3013
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