Falling Leaves, Pumpkin Spice and MDS Changes

October 1st is right around the corner which means new MDS changes. While there are fewer changes as compared to 2023, this year brings several important updates. So, sit back with your pumpkin spice latte and read on for the key MDS update information you need to know…

CMS Posted the MDS changes to the MDS 3.0 RAI User’s Manual version 1.19.1 in early August which included the following:

Section GG

The Discharge Goal column is removed in the following items:

• • • Self-Care
    • Mobility
    • CMS has removed the requirement to code discharge goals on the MDS, but key aspects of this section remain unchanged. Discharge care planning, identifying functional goals for care planning and discharge, and discussing these goals with the resident or their representative are still required.

Section I (Clarification for Septicemia)

A new coding tip for item I2100, Septicemia, clarifies that sepsis can only be coded as septicemia if there is evidence of both inflammation due to sepsis and a microbial process in the medical record. If these are not present, sepsis should be entered under I8000, Additional Active Diagnoses, with the relevant ICD code.

Section K (Revised Wording)

The revised definition of item K0520B, Feeding Tube, now excludes “medication” from its criteria. A feeding tube is defined as any tube used to deliver food, nutrition, or fluids directly into the gastrointestinal system. If the tube is used solely for medication administration, it should not be coded under K0520 as a nutritional approach.

The revised coding tip for K0520A, Parenteral/IV Feedings, clarifies that IV fluids can be coded if they are used to prevent dehydration, specifically for nutrition or hydration. Supporting documentation in the medical record must indicate that the additional fluid intake is clinically necessary for either purpose, but does not require both.

Section N

The following item is added:

• • • Anticonvulsant
    • New coding instructions for N0415K require facilities to check for a documented clinical indication for all anticonvulsant medications taken by a resident during the observation period. This addition enhances MDS monitoring, particularly since anticonvulsants are often used in place of antipsychotics. Facilities can also use this to ensure compliance with clinical standards and monitor for adverse effects.

Section O

• • • O0350. Resident’s COVID-19 vaccination is up to date based on the CDC recommendations.
    • For O0350, Resident’s COVID-19 Vaccination Status, facilities can determine a resident’s vaccination status by reviewing medical records or interviewing the resident, family, or caregivers. If the resident is not up to date and the facility has the vaccine, they should ask the resident if they would like to receive it.

Manual Deletion Requests

In addition, a Manual Deletion Request is now required in four specific cases (previously three):

• • • Incorrect A0410 Submission Requirement,
    • Record submitted for the wrong facility,
    • Record submitted not for OBRA or Medicare Part A purposes (new),
    • Inappropriate submission of a test record as a production record.

Key Takeaways

Section GG  changes are in alignment with the updates to the SNF QRP program and SPADES driven by the SNF 2025 PPS Final Rule. Moving forward, CMS is less interested in the Discharge Goals and more focused on the Discharge Function Score as a more accurate reflection of outcomes across  post-acute care.

Anticonvulsants have been added to Section N as a high-risk drug classification. The Care Area Worksheets are updated with this item in the Dental Care and Mood State Care Area Assessments (CAAs). The focus here is on appropriate use and monitoring of high-risk medications in the elderly population.

Lastly, COVID-19 vaccinations are added to Section O to assist in reporting vaccination status for  data collection for the new SNF QRP measure.

Take a few minutes this month to review how these changes might impact your workflow and put measures in place to ensure a smooth transition.

Specific areas to discuss:

• • • Is the current GG assessment process accurate and truly an IDT Assessment? (Check out Proactive’ s Section GG Toolkit)
    • What is the process for reviewing high risk medications and appropriate use?
    • Are all high-risk medications addressed on the care plan?
    • What is the process for gathering and recording vaccination status? Double check communication from admissions to clinical staff and review annual vaccination processes.

Make sure to work with your software vendors prior to 10/01 to ensure updates are in place. It is best practice not to open 10/01 MDS assessments until after software updates.

Resources:

• • • RAI User’s Manual
    • CDC COVID-19 Resources

Action Items!

• • • New MDS nurse or clinical leaders in need of training?  Register to join us on  November 4-6, 2024 for in-depth MDS Orientation Training
    • For those seeking certification in MDS through AAPACN, consider joining the next virtual offering of RAC-CT or RAC-CTA classes.