Q:
Our facility is being purchased by a new company. Does this affect the current patient’s MDS assessments and schedules? If so, how?
A:
If the CCN (CMS Certification Number) changes, then yes. Per RAI Chapter 2, pg. 2-5: There are two types of change in ownership (CHOW) transactions:
- The more common situation requires the new owner to assume the assets and liabilities of the prior owner and retain the current CCN. In this case:
- The assessment schedule for existing residents continues, and the facility continues to use the existing provider number.
- Staff with QIES user IDs continue to use the same QIES user IDs.
- There are also situations where the new owner does NOT assume the assets and liabilities of the previous owner. In these cases:
- The beds are no longer certified (through the former provider/owner)
- There are no links to the prior provider, including sanctions, deficiencies, resident assessments, Quality Measures, debts, provider number, etc.
- The previous owner would complete an OBRA Discharge assessment – return not anticipated, thus code A0310F = 10, A2000 = date of ownership change, A2100 = 02 for those residents who will remain in the facility.
- The new owner would complete an Admission assessment and Entry tracking record for all residents, thus code A0310F = 01, A1600 = date of ownership change, A1700 = 1 (admission), and A1800 = 02.
- Staff who worked for the previous owner cannot use their previous QIES user IDs to submit assessments for the new owner as this is now a new facility. They must register for new user IDs for the new facility.
- Compliance with OBRA regulations, including the MDS requirements, is expected at the time of survey for certification of the facility with a new owner.
Eleisha Wilkes, RN, GERO-BC, RAC-CT, DNS-CT
Clinical Consultant
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