What happens in the MDS department when a building is being purchased by a new company? A colleague mentioned that since it’s a new NPI number, we may need to complete a discharge and entry on every patient. Is this true?


There are two types of change in ownership transactions. The more common situation requires the new owner to assume the assets and liabilities of the prior owner and retain the current CCN number. 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.

Example: If the Admission assessment was done 10 days prior to the change in ownership, the next OBRA assessment would be due no later than 92 days after the ARD (A2300) of the Admission assessment and would be submitted using the existing provider number. If the resident is in a Part A stay, and the 5-Day PPS assessment was combined with the OBRA Admission assessment, the next PPS assessment could be an Interim Payment Assessment (IPA), if the provider chooses to complete one, and would also be submitted under the existing provider number.

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. 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, and A2100 = 02, another nursing home or swing bed, 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.

Reference: RAI Manual pg 2-5


Brandy Hayes, RN, RAC-CT
Clinical Consultant

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