As foretold in the SNF PPS Final Rule, CMS was going to fine tune the MDS/RAI manual prior to October 1 when the new 2024 Fiscal Year starts. Generally, data such as this update comes much closer, sometimes even after the October 1 implementation date. Providers get a break for a change. Initial proposed changes were flagged in a release from CMS in April. These changes represent the most adjustment to the MDS across recent years.
Now, it is important to note that I am not an MDS expert. I rely on people (have people) who are for specificity. I’m a policy guy and an econ and finance guy so my expertise lies on a macro level vs. the MDS micro level. To that end, I’m posting CMS’ summary of the 60 changes made here: mds-3.0-rai-manual-v1.18.11_draft_to_final_changes
For SNFs, it’s important to note the dates and assessment timing. By this I mean, the changes made to the RAI manual go into effect 10/1/23. Target assessment dates matter. Per CMS: “The item sets that are effective October 1, 2023 have had significant changes, including the omission and addition of many items. It is the target date of the assessment that identifies the required version of the item set, and, because of the substantial changes in the item sets, they are not interchangeable. Therefore, providers may not change target dates on assessments crossing over October 1, 2023.”
Basically, the above means that providers can not submit a modification to change a target date on an assessment completed prior to October 1, 2023 to a target date on or after October 1, 2023. They also can’t submit a modification to change a target date on an assessment completed on or after October 1, 2023 to a target date prior to October 1, 2023. This is similar to the process requirement when SNFs went from MDS 2.0 to MDS 3.0.
Questions remain around some specifics, particularly changes to Section GG, now required for all seniors in a building. There is also a new tool for mood scores that will likely cause folks to have to retrain to adjust the interview process. Improving the interviewing process ties to capturing depression for reimbursement.
As this data dropped yesterday, my advice to providers is get it (new manual and changes), read it, and put together a quick action plan to clarify anything not understood (trade associations can help as can I to anyone who drops a comment or emails me at rhislop@h2healthllc.com). Getting staff educated and running some parallel assessments for hands-on implementation closer to 9/30 will also be helpful. If you are using, as most SNFs likely are, MDS software, get to your provider on Monday and demand from them, info. on how they are going to get these changes implemented and maybe, provide some resources for education.
The full RAI manual is available here: final_mds-3.0-rai-manual-v1.18.11_october_2023
TGIF!