In April 2018, the Centers for Medicare and Medicaid Services (CMS) threw yet another curveball at (MDS) coordinators and skilled nursing facilities (SNFs) across the country. CMS’ original plan to introduce RCS-1 (resident classification system, the proposed new federal payment system) was overturned and replaced by the now proposed patient driven payment model (PDPM). This new payment model does have similarities to the previous RCS-1, but there were improvements made to increase payment accuracy.
The long-term post-acute care (LTPAC) industry is bracing itself for yet another major change in 2018: Resident Classification System-1 (RCS-1). This new Medicare payment model is only months away, with an estimated start date of October 1, 2018. RCS-1 has the potential to turn things upside down for providers that are not sufficiently prepared.
October 1, 2016 brought forth some significant changes to the Resident Assessment Instrument (RAI) Manual used by minimum data set (MDS) nurses throughout the country.
The RAI Manual is essentially an MDS nurse’s bible. It explains how to code and provides the rational for coding every single item on the MDS. If you have a question, it has the answer. My manual has never been far from me and the many notes and dog eared pages throughout it are a testament to that.
Today, the manual can be referenced online, so there is no need to carry the five inch binder around (although I still keep mine in the trunk of my car just in case). While the online version is a much better travel companion, I feel like we are not able to really dig our heels in and read it. For that reason, some items are much more likely to be miscoded in this new era of technology. Here are some of the most common areas I've found in which miscoding occurs:
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Quality Assurance/Performance Improvement (QAPI) regulation was advanced as a part of the Affordable Care Act (ACA) of 2010, but the basic premise is not entirely new to long-term post-acute care (LTPAC) providers. The initiative expanded the existing Quality Assessment and Assurance (QAA) provision, thus “reinforcing the critical importance of how nursing facilities establish and maintain accountability…in order to sustain quality of care and quality of life for nursing home residents.” The Centers for Medicare and Medicaid Services has linked these initiatives to reimbursement, furthering the underlying tenet of value-based purchasing-paying for performance based upon resident-centric outcomes.
QAPI takes the QAA regulations further by incorporating root cause analysis and performance improvement guidelines. While Quality Assurance QA is the assessment of how well the facility is doing, Performance Improvement (PI) is the application of corrective actions and improvement of performance in a monitored and measured approach. The expectation is that LTPAC providers will continue to question and refine processes until optimal outcomes are met. The goal of QAPI is to improve processes in the delivery of care and ultimately improve patients’ quality of life, as well as overall quality of care.If you work in a Long Term Post-Acute Care (LTPAC) setting, you know that in our field the only constant is change. There is, however, one process that has been with us, in one form or another, for quite a long time. Until recently, Quality Assurance and Performance Improvement were two separate processes. These have since been streamlined into what we now know as the QAPI (Quality Assurance/Performance Improvement) process. Let’s start off with the CMS definition of QAPI:
Effective October 1, 2016, Skilled Nursing Facilities (SNF) are required to submit additional functional and quality measure data via patient assessments to the Centers for Medicare and Medicaid Services (CMS). This information will be gathered from the revised Minimum Data Set (MDS) 3.0 Section A and a new Section GG. Along with these revisions, a new MDS assessment type of an SNF Medicare Part A PPS discharge assessment for when a Medicare Part A stay ends, will be implemented.
The newest update from the Centers for Medicare and Medicaid Services (CMS) was just released in August and I want to share some specifics about the upcoming changes to the Resident Assessment Instrument (RAI) Manual. The RAI Manual changes are effective for October 1, 2016. Most of us have heard about the new section GG, but there are some other notable changes as well:
The new Section GG will be in effect on October 1, 2016 for Long Term Care Facilities using the MDS 3.0 for payment. Although the new Resident Assessment Instrument (RAI) manual has not been released, we are able to extrapolate the majority of the information from our LTAC cousins who are already using this new section.