F641 Accuracy of MDS Assessments – Revised LTC Surveyor Guidance

F641 Accuracy of MDS Assessments – Revised LTC Surveyor Guidance

CMS and the Department of Health & Human Services released an updated version of the LTC Surveyor Guidance on March 10, 2025. This update, which revises the earlier January 16th release, takes effect April 28, 2025—so mark your calendars.

One key change impacts how surveyors are directed to review the Accuracy of MDS Assessments (F641). This area has been expanded, and now includes what used to be covered under F642 (Coordination/Certification of Assessment)—which is officially being retired.

Here’s where it gets serious:

Surveyors are now being told to report inaccurate MDS coding directly to the Office of Inspector General (OIG)—bypassing the CMS Regional Office and the Medicare Fraud Control Unit—if these three red flags are present:

• • A pattern (think: 3 or more residents) of the same inaccurate coding by the staff member who signed off on the assessment in Z0400
  • There’s concern the staff member knew the coding wasn’t accurate
  • The surveyor believes the inaccuracy was willful and intentional (yes, it’s subjective—and they get to decide)

What’s the takeaway?

CMS is doubling down on the importance of accurate MDS assessments. That accuracy directly impacts resident care, quality measures, and reimbursement. This isn’t about avoiding modifications to assessments—those are still allowed. But facilities must make sure that what’s documented truly reflects the resident’s status during the look-back period.

With surveyors now encouraged to escalate concerns to the OIG, it’s more important than ever that MDS coordinators are fully trained, have the right tools, and feel supported in their role. Bottom line: stick to the guidance in the MDS 3.0 RAI Manual and make sure your team is confident and compliant.

Next Steps: Contact Proactive to schedule a QA compliance review of MDS accuracy and for training opportunities including MDS orientation and mentorship support.