Ask Diane: How do CATs differ from RAPs?
Q: How do the Care Area Triggers (CAT) in the new MDS 3.0 draft differ from the Resident Assessment Protocols (RAP) in the MDS 2.0?
Diane: RAPs are “problem-oriented frameworks for additional assessment based on problem identification items (triggered conditions),” according to the RAI users manual. In the proposed rule for FY 2010 payment updates for SNFs, which was released on May 1, the Centers for Medicare & Medicaid Services (CMS) proposed to change the name of these tools from RAPs to CATs. Although fundamentally the same, there are some differences between RAPs and CATs.
First of all, the updated MDS 3.0 Draft Item Set includes 20 CAT problem areas, increasing the number from 18 RAP problem areas on the MDS 2.0. The two new problem areas are ‘Pain’ and ‘Return to Community Referral.’
Secondly, CATs are better able to adapt to changes in standards of care. Since the domains RAPs address are specified in regulation, it is difficult to make changes to account for modifications to the standards of care. CMS proposed to remove the listing of domains from the regulations and instead direct people to the RAI manual for information about the domains. This way, CMS can simply revise the manual to incorporate changes to the standards of care, rather than go through the rule making process.
Finally, CATs change the way facilities should approach the documentation. The RAP summary includes an instruction to describe the nature of the condition, complicating factors, risks, and referrals for the resident’s problem area. However, many facilities are unsure if separate documentation is required or the facility can just indicate where the documentation is in the clinical record. As a result, many facilities are writing detailed RAP notes covering the areas outlined in the instructions, in addition to the regular documentation in the clinical record.
The CAT summary omits the instruction to describe these items, clarifying that no additional documentation is required, but this information must be documented somewhere in the clinical record. Although this may save time for facilities that were writing separate RAP notes, it puts more pressure on the person doing the initial documentation because he or she must be sure to include all the information required by the CAT summary.
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Diane Brown
Diane Brown is a long-term care regulatory specialist and lead educator for HCPro's MDS 3.0 Boot Camp and Medicare Boot Camp-Long-Term Care Version. She is also a long-term care consultant with over 25 years of operational experience in healthcare. For Diane's complete bio, visit the About page.
Diane has written 240 posts.
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