IPA is an optional SNF PPS stand-alone MDS item set under PDPM

The Interim Payment Assessment (IPA) is an optional SNF PPS stand-alone MDS item set under PDPM. The IPA can be completed when providers determine that the resident has experienced changes to his or her clinical condition that would be sufficient to change payment in any of the five PDPM components or in the overall payment for the resident. It is the only PPS assessment, beyond the Initial PPS assessment, that will be able to change a resident’s Medicare rate. The rate calculated from the IPA pays for all covered Medicare Part A days from the ARD of the IPA until the Part A discharge, or until another optional IPA is completed.

In Chapter 2 of CMS’s RAI Version 3.0 manual (Version 1.17.1), CMS offers the following information regarding IPA scheduling and completion:

  • Optional assessment.
  • ARD (item A2300) may be set for any day of the SNF PPS stay, beyond the ARD of the 5-Day assessment.
  • Must be completed (item Z0500B) within 14 days after the ARD (ARD + 14 days).
  • Authorizes payment for remainder of the PPS stay, beginning on the ARD.
  • Must be submitted electronically and accepted into the QIES ASAP system within 14 days after completion (item Z0500B) (completion + 14 days).
  • The ARD for an IPA may not precede that of the 5-Day assessment.
  • May not be combined with any other assessments (PPS or OBRA).

Effective Use of the Optional IPA

Facilities need to have strong processes in place to promptly identify changes that may impact the PDPM case-mix group classifications. This requires (1) clarity on the resident’s baseline status for each component reported on the 5-day assessment and (2) systems in place to monitor for any changes that may impact PDPM classification for at least one the five PDPM components. Some systems and processes that are helpful in identifying changes in condition on a daily basis include: clinical meeting processes, communication systems, and electronic medical record alerts. These systems/processes should allow for prompt identification of changes in clinical status and care needs in areas such as:

  • Changes in cognition
  • New orders (i.e., mechanically altered diets, IV medications, respiratory therapy, etc.)
  • Presence of swallowing disorder
  • Changes in functional status impacting the GG Function Score
  • New diagnosis
  • New or deteriorating wounds

Medicare payment changes on the ARD of the IPA assessment, so it is important that the ARD is scheduled at the time the clinical change occurs. If a change that impacts payment is not identified and considered for IPA until days after the change occurs, dollars will be lost for each day between the day of the change in condition/triggering event and the date of the ARD. Once the change is identified, good communication between the nurse assessment coordinator and the IDT is important to ensure that appropriate assessment data is collected. Keep in mind that Section GG is a required component of the IPA and will have a three-day look-back period that includes the ARD of the IPA plus the two preceding days. Additionally, resident interviews including the BIMS must be completed within the look-back period of the IPA ARD and preferably on or just before the ARD. As soon as the change prompting the IPA is identified and the ARD is set, the team members responsible for these assessments should be notified in order to prepare to collect this data.

Proactive Resources for PDPM Support:

  • IPA Toolkit (Click here to download) that includes:
    • Interim Payment Assessment Policy that may be used as is or edited to suit the needs of the facility.
    • Clinical Meeting IPA Checklist to assist providers in tracking changes specific to the Part A resident that should be considered (with all other contributing factors) in the determination to complete and Interim Payment Assessment. Multiple residents may be listed on the checklist for ease of use during the facility’s normal daily clinical meeting.
    • Interim GG Documentation Tool to use as is or as a template for facility software to provide supporting documentation for interim GG coding decisions.
  • On-Demand PDPM Skilled Nursing Services webinar focused on justifying skilled nursing services under PDPM! This session is available on-demand to jump start your team’s skilled charting. (Click here to access)
  • Check out our PDPM Nurse Charting Guidelines including documentation guidance for critical NTA item supportive documentation as well as Clinical Categories! (Click here to download)
  • PDPM Essentials for Physicians & Pharmacy On-Demand webinar (Click here to access).

Proactive experts can help to meet your goals for staff development and successful PDPM implementation. Contact us for systems, coding, documentation, and auditing and monitoring support.

Learn more about Proactive’s PDPM Audit & Coding Support Partnerships here.

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

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