In the past, when there have been significant updates/revisions to the RAI Manual, there has been changeover in the MDS Staff in our facility. How do you recommend that we prepare should this occur again?



While expecting change doesn’t make it any easier, it can inspire us to stay prepared for changes by taking proactive steps. One proactive step to prepare for change in the MDS department is to have staff cross-trained in all aspects of the RAI process.  Always make sure you have “back-up” staff trained in the following RAI components:

      • Scheduling of the MDS
      • Coding of the MDS item sets and CAAs
      • Completion of the Care Plan
      • Verification of completion of the MDS, CAAs and Care Plan and the signatures required for this
      • Transmission of the MDS and obtaining the final validation reports
      • Reconciliation of the transmitted assessments

Should you be unable to enroll back-up staff in a formal RAI training course as quickly as needed, CMS has free training resources on their website at https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/nursinghomequalityinits/mds-30-training-archive-

Of course, in order to transmit MDS assessments and access validation reports, you must ensure  back-up staff have obtained the necessary log-in, password and training for the iQIES system.

In the event that your MDS staff leave your facility before they have completed/signed for any MDS items they initiated the RAI manual provides the following guidance:

If an individual who completed a portion of the MDS is not available to sign it (e.g., in situations in which a staff member is no longer employed by the facility and left MDS sections completed but not signed for), there are portions of the MDS that may be verified with the medical record and/or resident/staff/family interview as appropriate. For these sections, the person signing the attestation must review the information to assure accuracy and sign for those portions on the date the review was conducted. For sections requiring resident interviews, the person signing the attestation for completion of that section should interview the resident to ensure the accuracy of information and sign on the date this verification occurred.

Janine Lehman, RN, RAC-CT, CLNC
Director of Legal Nurse Consulting

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