The final RAI Manual for October 1, 2019 was released on September 18. The good news is that there are no surprises! I have to say I was really happy with the examples that have been added throughout the various sections. This was definitely a much needed update. I have highlighted below the items I found to be the most noteworthy.

Interim Payment Assessment (IPA)

IPAs remain “optional” assessments that may be completed by providers in order to report a change in the resident’s PDPM classification. We will only want to do an IPA if the resident has a decline that causes a major change in the resident’s payment for PDPM.

Section A

Optional State Assessment (OSA) – “Providers will submit the Optional State Assessment (OSA) records to the QIES ASAP system just as they submit all other MDS assessments. The OSA is not a federally required assessment. Each state will determine if the OSA is required and when this assessment must be completed.”

Section C

C0100 - Also clarified is how facilities will handle the PDPM calculation if the BIMS is not completed (unplanned discharge). The facility will now answer “No” to C0100, which will indicate that the BIMS should not be completed. This will allow the staff to answer the staff assessment and generate a score to be used in the calculation of the speech component of PDPM. This is a definite win for facilities!

Section I

I0020 and I0020B – I am excited to see that there was additional information added to Section I regarding the facility determination of the primary diagnosis. The RAI has now clarified that acute diagnosis should not be used as a primary diagnosis in I0020B.

In the instance where a resident had a CVA, we do not use the CVA as the primary diagnosis; instead, we would use something like hemiplegia/hemiparesis or another late-effect diagnosis related to the CVA.

I5600 – OK, folks, this is not a change, but it’s still worth noting. Checking I5600 will give you one point in the Non-Therapy Ancillary (NTA) category of PDPM. This item includes risk of malnutrition as well. Every point is important in the NTA category, so grab them when you can!

Section J

Section J has some new items to be aware of including J2100 – Recent surgery requiring active SNF care. Remember, this is recent history of major surgery during the inpatient stay that preceded the resident’s Part A admission which can affect a resident’s recovery.

Also added to section J is J2300 – J5000: Recent Surgeries Requiring Active SNF Care and some very specific instruction has been given. Code surgeries that are documented to have occurred in the last 30 days, and during the inpatient stay that immediately preceded the resident’s Part A admission, that have a direct relationship to the resident’s primary SNF diagnosis, as coded in I0020B.

Check off each surgery requiring active SNF care as defined above, as follows: Surgeries are listed by major surgical category:

Section K

So here is another PDPM gold mine that you want to make sure to capture! K0510A includes any and all nutrition and hydration received by the nursing home resident in the last seven days either at the nursing home, or at the hospital as an outpatient or an inpatient, provided they were administered for nutrition or hydration. “Parenteral/IV feeding—the following fluids may be included when there is supporting documentation that reflects the need for additional fluid intake specifically addressing a nutrition or hydration need. This will allow us to capture IV fluids for hydration during the entire seven-day look back…which included the hospital stay if the ARD is adjusted accordingly. If the fluids are >500ml per day on average for seven days you will receive seven points in the NTA component. If the fluids are >500ml per day on average for seven days you will receive three points in the NTA component. This will be an amazing advantage in the calculation of your NTA PDPM rate.

Contact Richter

Do you have questions about RAI updates, or other LTPAC clinical challenges? Call Richter’s clinical education consultants at 866-806-0799 to schedule a free consultation.

Jennifer Leatherbarrow RN, BSN, RAC-CT, IPCO, QCP, CIC, is Manager of Clinical Consulting for Richter.