Archive for: Preparation
Next SNF ODF May 24
The next SNF ODF will be held Thursday, May 24 at 2 p.m. EST.
The program’s agenda, which is subject to change, is available at www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/Downloads/AgendaSNFLTC052412.pdf.
March 1 SNF ODF Notes
CMS addressed a number of issues in today’s Open Door Forum (ODF) including an RAI User’s Manual errata document that was posted with errors, Change Request (CR) 7717, the latest QM information, and the upcoming release of the new combined Notice of Medicare Noncoverage (NOMNC). See the complete notes below:
- After using a web streaming platform for January’s ODF, CMS has decided to return to the current call format. Numerous problems were reported in January. CMS will look to place the audio file from January on its website (it was initially accessible for three business days immediately following the ODF). For today’s call, the encore will be available Monday (3/5) to Wednesday (3/7) at midnight.
- Reminder: the MDS 3.0 National Conference will be held next week in St. Louis.
The RAI User’s Manual errata document
- CMS posted an errata document on February 29 related to the updated RAI User’s Manual. The information on pages 1-4, which addressed the specific issues and a pending resolution, are accurate; however, pages 5-11 contained incorrect information. CMS is correcting the document, which will be posted tomorrow (3/2) or at some point next week. It will have a different file name and the revisions will be explained within the document. Additional errata clarification documents will be added as needed. Corrected pages will contain an “(R)” in the footer.
- Errata documents can be found on the MDS 3.0 Training page.
Claim submission clarifications
- CMS offered clarification regarding CR7717 for SNF and swing bed Medicare Part A providers. CR7717, which was released on Jan. 26, 2012, cites the removal of the occurrence code 16 reporting requirement. As of that date, SNF and swing bed providers no longer needed to report occurrence code 16 on claims to indicate the last day of therapy services. After further review, it was decided that this requirement was unnecessary, hence its discontinuation.
- If your facility has claims returned, the quickest way to get a resolution is to contact your MAC directly to alert them of situation. The MAC will submit questions to the CMS system maintainer for appropriate research. If you are having multiple claim inquiries, contact CMS directly as it could be a national issue.
Survey updates
- Revisions have been made to the traditional nursing home survey process. The QM reports are going to once again be used and CMS has been preparing the traditional survey process so surveyors can begin using the QM reports. The three QM reports that providers are issued (Facility Characteristics, Facility Level Report, and Resident Level Report) will track the new QMs. Those reports will not use all QMs in existence, for example immunizations have been removed from the reports because it was felt surveyors did not need to spend time on immunizations. As a result, the QM list is much shorter than it used to be. The major change to the forms, aside from their redesign so the language matched that of the QMs themselves, is the thresholding that surveyors use to pick out topics for the survey is now going to be nationally-based rather than state-by-state. So where there is a threshold that exceeds the predetermined percentile, the facility will be compared on a national level and not just within its state as had previously been the case.
- A change in the survey process in Appendix PP of the State Operations Manual is pending. This includes changes to two major forms that facilities must turn in to surveyors: the 802 (roster sample matrix for the traditional survey) and the 672 (census), which is used by the traditional survey and QIS. These were released to facility programmers on Feb. 22 and are being programmed at this time.
ABN updates
- The NOMNC and Detailed Explanation of Noncoverage (DENC) are based on existing notices that have been combined, so they can be issued to both original Medicare beneficiaries and MA enrollees. The new NOMNC combines and will replace the current Notice of Medicare Provider Noncoverage (CMS-10123), which is issued to original Medicare beneficiaries, and the Notice of Medicare Noncoverage (CMS-10095), which is issued to MA enrollees. The new NOMNC retains the form number of the current original Medicare notice (CMS-10123) and takes on the name of the MA notice (Notice of Medicare Noncoverage).
- The new DENC combines and will replace the Detailed Explanation of Noncoverage (CMS-10124), which is issued to original Medicare beneficiaries, and the Detailed Explanation of Noncoverage (CMS-10095-DENC), which is issued to MA enrollees. The new DENC retains the form number of the original Medicare Detailed Explanation of Noncoverage (CMS-10124).
- The requirements for issuing these notices have not changed. The new notices will be posted within the next few days at: www.cms.gov/bni. Once the new notices are posted, providers will have a 60-day grace period to begin using the new combined notices. If you have any questions, contact CMS at revisedABN_ODF@cms.hss.gov and be sure to include NOMNC in the subject line.
If you were not able to ask a question during the Q&A segment of today’s call, CMS invites you to submit your questions to the SNF ODF mailbox (SNF_LTCODF-l@cms.hhs.gov).
The latest RAI changes: April 1 implementation
In January, CMS released the RAI User’s Manual changes that will take effect April 1. While some of the revisions are gratuitous in nature, such as slight wording adjustments or grammatical corrections, many present major reimbursement or resident care implications for SNFs. A basic breakdown of the changes is listed below:
- Adjustments to the PPS assessment windows
- New form set for Section A0310C
- Revised definition for activities of daily living (ADL) code 8
- Added specifications for weight gain and fluid status monitoring in Section K0310
- Section K0500 was replaced with two columns, similar to what’s found in Section O
- Type of discharge (planned versus unplanned)
- Check boxes replaced with value boxes (number of days) for quality measure (QM) items and care area assessments (CAA) in Section N0410
- Section Q overhaul, including the addition of Section Q0490
- Moisture associated skin damage as a CAA trigger
Version 1.08 of the RAI User’s Manual is available from CMS at www.cms.gov/NursingHomeQualityInits/45_NHQIMDS30TrainingMaterials.asp.
Stay tuned for information on HCPro’s March 27 webinar, which will feature Diane Brown and Frosini Rubertino’s expert analysis of the RAI changes, including the reimbursement impacts and outcome-based challenges facing SNFs.
Notes from the Jan. 19 SNF ODF
At the start of the Centers for Medicare & Medicaid Services (CMS) first web streaming SNF Open Door Forum (ODF), the overwhelming response to registration for the March MDS National Conference in St. Louis was addressed. The high volume exceeded hotel capacity, so a waiting list has been created, which currently has a few hundred people on it. CMS will try to accommodate as many attendees as possible, but realistically, not everyone who registered will be able to attend. For those individuals, the training materials will be available on the CMS website following the conclusion of the conference.
The latest revised RAI User’s Manual (effective April 1) is in the process of being posted on the MDS 3.0 Training Materials page. It should be available the week of Jan. 22. One of the major changes is the new requirements for planned and unplanned discharge assessments. Item A0310G is new and indentifies the type of discharge (planned or unplanned). Unplanned discharges no longer require pain interviews, and have been shortened from 111 maximum questions to 72. This does not factor in skip patterns.
Due to the high number of questions received related to the MDS interviews, CMS reminded listeners that items such as the PHQ9 are standardized instruments that have been tested and proven to be reliable. When completing interviews, SNFs should follow the interview instrument instructions and remember that the interviews are intended to access residents’ status from their perspective. CMS referred to reports that some facilities are not completing interviews with capable residents, which is a citable offense.
CMS has also received many questions pertaining to further COT clarification, especially involving setting the ARD. CMS is in the process of developing short- and long-term solutions for this issue.
Lastly, CMS is still on track to post the quality measures on the Nursing Home Compare website on Thursday, April 19. Providers will get an early preview of their own scores in late January. CMS has not decided which quality measures will be used for the Five-Star Quality Rating System, but that should be determined by April.
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