Long-Term Care

Notes from the December 9 SNF ODF - RUG-IV delay repealed!

MDS 3.0 Insider, December 13, 2010

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During the December 9 SNF Open Door Forum (ODF), CMS provided callers with updated information about the repeal of the RUG-IV partial delay, Quality Indicator Survey (QIS) process, and the SNF advanced beneficiary notice (ABN).

Some highlights from the ODF are as follows:

  • US House of Representatives passed Senate Amendment to H.R. 4994, the Medicare and Medicaid Extenders Act of 2010, by a vote of 409-2 earlier today. This legislation, which was passed by the Senate on December 8, includes the extension of the therapy cap exceptions process until Dec 31, 2011 and repeals the RUG-IV delay enacted by healthcare reform. Therefore, SNFs will continue using the RUG-IV system, as they have been since the October 1 implementation of the MDS 3.0, rather than having to switch to the hybrid system CMS has been working to develop. The legislation will now be sent to President Obama to sign into law.
  • CMS official Thomas E. Dudley, MS, RN, clarified that facilities who incorrectly coded item A0310E in the past do not need to submit a correction. According to the CMS website, the transition document they released indicated that this item “should be coded as ‘1’ for the initial MDS 3.0 assessment for all existing residents; however, this guidance was overlooked on many of the assessments that were submitted. During the November 9, 2010 National Provider Call direction was provided indicating that assessments that were coded as a ‘0’ would need to be corrected and resubmitted. CMS has reconsidered the matter and has concluded that providers do not need to submit corrected assessments where item A0310E may have been miscoded. Providers should follow the directions outlined in Chapter 3 Section A of the MDS 3.0 RAI User’s Manual for the coding of A0310E from this point further.”
  • The QIS team is working on analysis of the QIS process related to the MDS 3.0. Information regarding the QIS process will eventually be incorporated into the State Operations Manual (SOM). A CMS official stated that there are very few measures used in the QIS that are related only to the MDS. The QIS process will continue as usual minus the use of those MDS-only items. The MDS-only items are expected to be incorporated in the QIS process in April 2012.
  • There was a change in management in the group of CMS officials working on the revised SNF ABN, leading to a delay in the process. The team is committed to completing new instructions for the SNF ABN but CMS officials could not provide a timeline for when this will occur. They hope to have more information during future ODFs.
  • CMS has been having trouble uploading the revised Appendix PP of SOM that was released in October. Currently, the website displays the version from 2009. However, the revised version can be found in Transmittal 66.

The next SNF ODF will be January 27 at 2 p.m. eastern.

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