On December 23, 2022, the Centers for Medicare and Medicaid Services (CMS) provided a sneak peek at all the Minimum Data Set (MDS) version 1.18.11 item sets that are planned to go into effect October 1, 2023. The changes are significant in nature and will require advanced planning to assure your nursing facility is fully compliant. There is a definite focus on the patient’s voice that the interdisciplinary team (IDT) will need to pay close attention to when completing assessments.

To understand the importance CMS is placing on patient voice, Section A “Race/Ethnicity” has been separated and expanded to allow the patient more options when answering the following questions:

• “Are you of Hispanic, Latino/a, or Spanish origin?”
• “What is your race?”

Other interviews include whether there is any lack of transportation, and how that could impact the patient’s ability to make appointments and obtain medications. The new health literacy interview will ask the patient about their ability to read instructions, pamphlets, or written material from the physician or pharmacy. Items in Section Q “Participation in Assessment” are also centered around the patient’s voice and the patient’s goals.

CMS has added another facility process component of the MDS. Currently, the drug regimen review in section N asks “Did a complete drug regimen review identify potential clinically significant medication issues?” with two follow up questions as to what the facility did in the event a medication issue occurred. Questions in section A will ask whether (at the time of discharge) the facility provided the resident’s current reconciled medication list to the subsequent provider, and the route by which the information was provided. It will also be reported on the MDS if the facility provided a current reconciled medication list to the resident, family, or caregiver upon discharge.

Section G “Functional Abilities” will no longer be a component of the MDS. Section GG “Functional Abilities and Goals” will take its place, which requires facility planning to meet the expectations that “an interdisciplinary team of qualified clinicians is involved in assessing the resident during the three-day assessment period.” Section GG is based on a patient’s “usual” function, which can be subjective and open to interpretation unless documentation clearly supports the team’s decision. Particularly when considering CMS expectations, “it is important to note that completion of the MDS does not remove a nursing home’s responsibility to document a more detailed assessment of particular issues relevant for a resident. In addition, documentation must substantiate a resident’s need for Part A SNF-level services and response to those services for Medicare SNF PPS.”

Nutritional approaches have expanded to four options rather than two. The facility will report if the approaches were in place upon admission, which is considered days one through three of the stay, performed while not a resident, performed within the last seven days while a resident, and at discharge.

Other changes include Section N “Medications Received” will be renamed “High-Risk Drug Classes: Use and Indication”. The facility will want to assure that all high-risk drugs have an indication for use. Drugs considered high-risk for MDS purposes include medications such as diuretics, hypoglycemic, antibiotic, as well as antipsychotics, antianxiety, opioids, etc. Special treatments, procedures, and programs have been reformatted and require more specific information as well.

Richter’s clinical consulting team is ready to assist your organization with the changes that will go into effect on October 1, 2023. Be on the lookout for educational opportunities that will address facility processes, medical record documentation to support MDS coding, and instruction for using the MDS to develop a resident-centered care plan. This is also a good time to think about updates to PointClickCare configuration and supportive documents that will be required with these upcoming changes.

References:

United States, Department of Health and Human Services Centers for Medicare and Medicaid Services. FY 2023 42

CFR Parts 413 and 483 Vol. 87 No. 148 (August 3, 2022) retrieved 10/4/2022 from: Federal Register :: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2023; Changes to the Requirements for the Director of Food and Nutrition Services and Physical Environment Requirements in Long-Term Care Facilities

Centers for Medicare and Medicaid Services Long Term Facility Resident Assessment Instrument (RAI) MDS 3.0 User’s Manual Version 1.17.1 October 1, 2019 retrieved September 26, 2022 from Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual | CMS

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