More info on RAI updates
CMS released version 1.07 of the RAI User’s Manual August 31. While this new version of the manual included a lot of changes, many of them were to solve formatting mistakes, correct minor issues, and clarify certain aspects of the assessment process. However, some of the most notable changes included in this version of the manual are as follows:
- New assessment schedule: CMS made changes to the assessment schedule by changing the assessment reference date (ARD) window and allowable grace days for most assessments. This was done in an effort to eliminate overlap from different assessments and capture the most accurate representation of residents’ conditions and services provided. However, the new assessment schedule essentially makes the window to set the ARD smaller, which doesn’t leave much wiggle room for facilities.
- Introduction of the Change of Therapy (COT) OMRA: Complete when the intensity of therapy, which includes the total reimbursable therapy minutes (RTM), and other therapy qualifiers such as number of therapy days and disciplines providing therapy, changes to such a degree that the beneficiary would classify into a different RUG-IV category than the RUG-IV category determined by the previous Medicare assessment. The observation period for the COT OMRA is a rolling seven-day window, with the first window ending seven days after the ARD of the previous Medicare assessment. The requirement to complete a change of therapy is reevaluated with additional seven-day COT observation periods ending on the 14th, 21st, and 28th days after the most recent Medicare payment assessment ARD and a COT OMRA is to be completed if the RUG-IV category changes. If a new assessment used for Medicare payment has occurred, the COT observation period will restart beginning on the day following the ARD of the most recent assessment used for Medicare payment.
- Introduction of the End of Therapy – Resumption (EOT-R) OMRA: In cases where therapy resumes after the EOT OMRA is performed and the resumption of therapy date is no more than five consecutive calendar days after the last day of therapy provided, and the therapy services have resumed at the same RUG-IV classification level that had been in effect prior to the EOT OMRA, an EOT-R OMRA may be completed. The EOT-R reduces the number of assessments that need to be completed and reduces the number of interview items residents must answer.
- New definition for active diagnoses in Section I: Active diagnoses are physician-documented diagnoses in the last 60 days that have a direct relationship to the resident’s functional status, cognitive status, mood or behavior, medical treatments, nursing monitoring, or risk of death during the seven-day look-back period.
- Clarification of the group therapy definition: The new RAI User’s Manual defines group therapy as the treatment of four residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or assistant who is not supervising any other individuals. It is important to also note that the minutes being coded on the MDS are unadjusted minutes, meaning, the minutes are coded in the MDS as the full time spent in therapy. However, the software grouper will allocate the minutes appropriately. In the case of group therapy, the minutes will be divided by four. Even if a resident could not attend or finish a group therapy session, the minutes will be divided by four. If group therapy is not planned for four participants, the minutes cannot be counted on the MDS.
- Removal of the line-of-sight provision: Therapy students are no longer required to be in line-of-sight of the professional supervising therapist/assistant. Within individual facilities, supervising therapists/assistants must make the determination as to whether or not a student is ready to treat patients without line-of-sight supervision. Additionally all state and professional practice guidelines for student supervision must be followed.
- Revised definition of how to manage resident skin problems under Section M: The new version of the manual contains the following information about item M1200D, Nutrition or Hydration Intervention to Manage Skin Problems:
- The determination as to whether or not one should receive nutritional or hydration interventions for skin problems should be based on an individualized nutritional assessment. The interdisciplinary team should review the resident’s diet and determine if the resident is taking insufficient amounts of nutrients and fluids or are already taking supplements that are fortified with the US Recommended Daily Intake (US RDI) of nutrients
- Additional supplementation above the US RDI has not been proven to provide any further benefits for management of skin problems including pressure ulcers. Vitamin and mineral supplementation should only be employed as an intervention for managing skin problems, including pressure ulcers, when nutritional deficiencies are confirmed or suspected through a thorough nutritional assessment (AMDA PU Guideline, p. 6). If it is determined that nutritional supplementation (i.e., adding additional protein, calories, or nutrients) is warranted, the facility should document the nutrition or hydration factors that are influencing skin problems and/or wound healing and “tailor nutritional supplementation to the individual’s intake, degree of under-nutrition, and relative impact of nutrition as a factor overall; and obtain dietary consultation as needed,” (AMDA PU Therapy Companion, p. 4)
- It is important to remember that additional supplementation is not automatically required for pressure ulcer management. Any interventions should be specifically tailored to the resident’s needs, condition, and prognosis.
- Care Area Assessment (CAA) tips: CMS revised some of the CAA tips, removed a few others, and added some different tips and clarifications. See pp. 4-11 and 4-12 for the new and revised CAA tips.
The updates included in this version of the RAI User’s Manual will become effective as of October 1.
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MacKenzie Kimball
MacKenzie Kimball is a Managing Editor in HCPro's long-term care division. She is the editor of the monthly newsletter PPS Alert for Long-Term Care and the MDS 3.0 Update e-newsletter.
MacKenzie has written 321 posts.
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Comments
In october when we do change of therapy assessments for medicare residents will this also be for residents under managed care. Just wandering if this would be different since these assessments will not be transmitted.
Scenario: Last day of therapy 9/25, missed 26, 27, 28, resumed therapy 9/29. Previous RUG was RUB; new RUG is RMB. Is this coded as EOT-R or E/SOT?
(Correction for dates for question submitted re: EOT-R or E/SOT: Use dates in October instead of September)
In october when we do change of therapy assessments for medicare residents will this also be for residents under managed care. Just wandering if this would be different since these assessments will not be transmitted.
I think it’s ok,don’t care much about it.
I’d like to wear a replica Chanel handbag. But do you know where I buy it? What do you suggest I do? Sounds like you’re ready to have a try. Or the Chanel 1112 will also make you happy. Will you like to dance with them? If so, come and join with me.
IS it permitted to site an entry in an icp within your CAA note? The care plan is the end product but also considered a part of the residents’ record. Please comment.
Just wondering about using grace days with ongoing cot monitoring. For example, If Monday October 10th (day 14) is the ARD for my 14 day assessment, my cot window would be Tuesday thru the following Monday. Say no change in the intensity of therapy occurs, when it comes time for my 30 day assessment, I would like to use a grace day and have my ARD be Wednesday Oct 26 (day 30) – can I do that or must my ARD always fall on the last day of the usual cot monitoring week? I hope this make sense. Thanks!
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