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Q: I have always been told that only three of the five potential grace days allowed for the 90-day PPS MDS can be used-because the first quarterly assessment must be completed within 92 days after the admission assessment. Is this correct?

Julia's PPS Chat, August 31, 2005

Welcome to this edition of PPS chat!

Remember when PPS reimbursement started? It seemed that everyone had questions about the use of grace days. Could they be used? If so, when could they be used? What about using grace days with the 90-day PPS MDS?

Read on to find out the answer-

Q: I have always been told that only three of the five potential grace days allowed for the 90-day PPS MDS can be used-because the first quarterly assessment must be completed within 92 days after the admission assessment. Is this correct?

A: Completing a quarterly OBRA assessment and 90-day PPS MDS as one assessment is a common combination. To answer your question, let's look at the two schedules for completing MDSs-the OBRA and PPS schedules.

In the OBRA schedule, the quarterly MDS must have an R2b completion date of no later than 92 days from the R2b date of the previous OBRA assessment. Page 2-16 of the updated Resident Assessment Instrument (RAI) User's Manual provides a chart that explains this requirement.

Looking at the PPS schedule of assessments, the 90-day PPS assessment can have an assessment reference date (ARD) between days 80 and 89, or 90 and 94 if you use grace days. Note that this is the ARD date, not the R2b signature date.

The updated RAI User's Manual states on pp. 2-36 and 2-37, "The facility must ensure that the completion date (R2b) will occur within 92 days of the R2b of the previous comprehensive or quarterly assessment. The ARD must also be set within the proper window for the Medicare requirement."

Therefore, depending on the timing of both your 90-day PPS MDS and your quarterly assessment, you will want to be cautious when using grace days for the 90-day PPS MDS. You might only be able to use three grace days to meet both scheduling requirements.

Be sure you meet all of the above time constraints. Also remember that you are not required to combine a PPS assessment with an OBRA assessment. You might want to do a separate quarterly assessment and then a 90-day PPS assessment using up to five grace days.

Review the chart in the RAI User's Manual-if you follow all of the guidelines that are listed, your assessment schedule should be right on track. Be sure to carefully maintain your schedule of MDS assessments that are due so that you don't miss completing an MDS.

Until we chat again-