The Interim Payment Assessment (IPA) is an optional assessment that may be completed to capture changes in a resident’s status and condition and to report a change in a patient’s PDPM classification. Providers determine when to complete an IPA, which may be any time after an initial/5-day assessment is completed. This “open-ended” guidance leaves facilities with the responsibility of developing a framework for clinical analysis and decision making regarding when to complete an IPA.

CMS has clarified that the SNF’s responsibility includes recognizing those situations that warrant a decision to complete an IPA in order to account appropriately for a change in patient status. Furthermore, CMS notes that while a SNF’s decision to complete the IPA itself is indeed optional, the SNF’s underlying responsibility to remain fully aware of (and respond appropriately to) any changes in a resident’s condition is in no way discretionary.

Strategies for Providers for COVID-19

Providers should have solid processes in place to identify and monitor changes in resident condition or PDPM classification that may warrant completion of an IPA assessment.

Changes in condition related to COVID-19 that may warrant completion of an IPA assessment include:

      • Decline in self-care or mobility functioning
      • Need for Ventilator or Respirator use while a resident
      • Placement of resident in infection isolation
      • Depression related to social distancing/lack of visitation
      • New onset of shortness of breath while lying flat for COPD patients with asthma, COPD, or chronic lung disease
      • Fever with pneumonia diagnosis, vomiting, or weight loss
      • New orders for Respiratory Therapy
      • New diagnosis of Respiratory Failure, Pneumonia, Septicemia
      • Use of oxygen
      • IV medications

Providers are encouraged to assess for and consider completion of the IPA and/or SCSA when changes in condition are identified, keeping in mind that these assessments cannot be combined. The criteria and guidance for the SCSA can be found in the RAI 3.0 User’s Manual.


Blog by Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, Director of Regulatory Services, Proactive Medical Review

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