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(December 2016 – KM, OTR/L)

Q: For the new CPT eval codes what exactly is counting as a standardized assessment? MMT is part of both OT and PT eval at my facility and does examine both body function and performance deficits but is not technically standardized. Does it count toward the number of assessments needed for a code? 

Answer:

(November 2016) Our November Questions and Answers are specific to MDS Section GG and/or the Quality Reporting Program and were taken from the SNF Quality Reporting Program Q&A Session held October 20, 2016. To see the original document, click here.

Usual Performance:

Q: The RAI manual, page GG-3 states, “Residents should be coded performing activities based on their “usual performance” (or baseline performance on admission), which is identified as the resident’s usual activity/performance for any of the self-care or mobility activities, not the most independent or dependent performance over the assessment period. Therefore, if the resident’s self-care performance varies during the assessment period, report the resident’s usual status, not the resident’s most independent performance and not the resident’s most dependent episode”.

The RAI manual, page GG-4 states, “For the Admission assessment, code the resident’s functional status based on an assessment of the resident’s performance that occurs soon after the resident’s admission. This assessment must be completed within 3 calendar days (days 1 through 3 of the Medicare Part A stay), starting with the date in A2400B, Start of most recent Medicare stay and the following two days, ending at 11:59 PM on day 3. The assessment should occur prior to the start of therapeutic intervention in order to capture the resident’s true admission baseline status.”

These directions present conflict.

A SNF that initiates therapy on the day of admission or the day after would not be able to capture resident performance over the 3 calendar day period, because therapeutic intervention would begin sooner. Potentially, the SNF would only have one shift for assessing the resident’s self-care or mobility performance.

#1: Is this acceptable to CMS to meet the requirement for assessment of Section GG usual performance?

#2: At the CMS SNF QRP Provider Training in Atlanta, attendees were advised that Section GG performance on the 5-day PPS assessment is intended to reflect baseline performance prior to admission to SNF. Based on the directions in RAI manual, including page GG-20, “record the resident’s usual performance during the assessment period”, the information shared at SNF QRP training is not accurate. Please confirm or clarify.

Answer: CMS Response to Question 1:

Answer: CMS Response to Question 2:

(November 2016) Our November Questions and Answers are specific to MDS Section GG and/or the Quality Reporting Program and were taken from the SNF Quality Reporting Program Q&A Session held October 20, 2016. To see the original document, click here.

Discharge Goals

Q: The RAI manual, page GG-13 “For the cross-setting quality measure, the Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function, a minimum of one self-care or mobility goal must be coded per resident stay on the 5-Day PPS assessment. Even though only one discharge goal is required, the facility may choose to code more than one discharge goal for a resident.”

RAI manual, page GG-13, “Use the 6-point scale to code the resident’s discharge goal(s). Do not use the “activity was not attempted” codes (07, 09, or 88) to code discharge goal(s). Use a dash (-) to indicate that a specific activity is not a goal. Of note, one goal must be indicated for either self-care or mobility. Using the dash in this allowed instance does not affect APU determination.”

These directions present conflict: CMS advises against the use of dashes due to it counting against the SNF in meeting the SNF QRP Reporting requirement. We recognize, the RAI manual states the use of a dash in one goal of Section GG will not affect the SNF QRP Reporting requirement, however we do not understand why a SNF cannot use the code 09, not applicable for the second goal if it is not applicable. Please advise.

Answer: CMS Response

(November 2016) Our November Questions and Answers are specific to MDS Section GG and/or the Quality Reporting Program and were taken from the SNF Quality Reporting Program Q&A Session held October 20, 2016. To see the original document, click here.

Clean up assistance

Q: The RAI manual, page GG-3 states, “Code 05, Setup or clean-up assistance: if the helper SETS UP or CLEANS UP; resident completes activity. Helper assists only prior to or following the activity, but not during the activity. For example, the resident requires assistance cutting up food or opening container, or requires setup of hygiene item(s) or assistive device(s).” Only one example is provided for self-care and one example for mobility. Please provide more examples addressing the following:

• Oral hygiene: resident is able to gather supplies for brushing/cleaning dentures. Upon completion of the task the toothbrush, tooth paste, denture cup are all left out and not returned to bedside dresser or holder.
• Eating: resident goes through buffet line for breakfast and eats independently, but does not clear the table.

Answer: CMS Response

(November 2016) Our November Questions and Answers are specific to MDS Section GG and/or the Quality Reporting Program and were taken from the SNF Quality Reporting Program Q&A Session held October 20, 2016. To see the original document, click here.

Transition

Q: CMS direction is still pending on how transition should be handled for patients admitted before 10/1/16 but discharged after 10/1/16. Does CMS expect Section GG to be coded on the discharge assessment? We anticipate CMS will not count these transition assessments in the QRP measure as there is no admission information to compare to discharge. Please advise.

Answer: CMS Response

(November 2016) Our November Questions and Answers are specific to MDS Section GG and/or the Quality Reporting Program and were taken from the SNF Quality Reporting Program Q&A Session held October 20, 2016. To see the original document, click here.

Use of dash and impact on SNF QRP measurement

Q: During the CMS SNF Open Door Forum on October 6 th, 2016, a question was asked about the use of a dash on the weight item in the MDS and whether that would count against the SNF for the Quality Reporting Program requirement, considering it is a covariate for one of the measures. The CMS consultant responded that she didn’t think it would count against SNF QRP. This response is in conflict with the information shared by CMS at the SNF QRP Provider trainings earlier this year and in conflict with the CMS SNF QRP Questions from Training – August 2016 document currently posted on the CMS SNF QRP website. This document states, “The Annual Payment Update threshold for FY 2018 is not based on the final calculation of a quality measure, nor complete stays. Rather it is based Skilled Nursing Facility Quality Reporting Program Frequently Asked Questions October 20, 2016 5 on the determination of the completion of the items necessary to calculate the quality measure, which we note includes the risk adjustment items.” Please advise.

Answer: CMS Response

(October 2016 – Steph, COTA Rehab Manager)

Q: When do the new PT and OT Evaluation codes start?

Answer:

(October 2016 – Cynthia – Rehab Manager)

Q: Can you provide information on the new CPT Codes for PT and OT?

Answer:

(August 2016- Liz, Rehab Director)

Q: When coding mobility in the new Sectio GG “Does the patient walk” and the answer is “yes” but they are unable to walk 50 feet how is this coded?

Answer:

(August 2016 – Sharon, PT Manager)

Q: As the PT and Manager of the Rehab Department, can I fill out Section GG and sign it? or does this have to be signed off by a nurse?

Answer:

(July 2016 – Deena, PT/Manager)

Q: When does the new MDS Section GG start and who is responsible for filling this out, therapy or nursing?

Answer:

(July 2016 – Joanne, COTA/Manager)

Q: Is there a rule in the SNF for seeing patients 6 or 7 days per week?  How would you schedule your staff?  Do you rotate weekends and take a day off during the regular work week? Any advice is appreciated!

Answer:

(June 2016 – SS, PT Manager)

Q: Can you tell me where in the rules it states that the therapy days and minutes can be counted on the MDS even if it is a “Medicare skip day?” We had a resident receive PT and OT services during the day and then went to the ER in the evening, was out over midnight, and then returned in the morning, in less than 24 hours. I want to include the mintues on the MDS, though our MDS Coordinator is saying we are not able to.

Answer:

(June 2016 – Sherri, OT)

Q: I have a referral for a Medicare Part B resident for feeding difficulties due to bilateral tremors. Is the correct G-Code “Self Care?” There are other factors such as positioning, environmental support, vision and health issues involved. What assessment tool would I use to report the modifier to Medicare?

Answer:

(May 2016 – Deb, PT)

Q: Our contract company just told us we are not allowed to write daily treatment notes any more. We were instructed to only write a note if there was an “event” or if something “atypical” happened. Is there a regulation that backs this up? I’m a bit hesitant to stop doing this.

(May 2016 – Becky, PT)

Q: Do the Medicare A regulations state anywhere that the minutes for a Rehab RUG score can’t be exact – For example, does it say somewhere that a RU can’t be 720 minutes exactly? If so, where can I find this?

Answer:

(April 2016 – Braydon, PT)

Q: Can we see a Med B and a Med A resident concurrently for treatment?

(April 2016 – Sue, MDS Coordinator)

Q: We are a Case Mix state (NY). When I verify the insurance of each resident what is the criteria I am supposed to use? Is it the resident’s insurance as of the cut-off date or the resident’s insurance as of the ARD date? 

Answer:

(March 2016– David, PT)

Q: This is my first student in the SNF setting. Can my PT student bill for services they perform with a Medicare PartA resident?

(March 2016- From Jenn, PT)

Q:I just started a new job and this facility does not have the therapists write a daily treatment note. I have always been taught to do this but my supervisor said it is not required. Can you tell me if it is required?

(February 2016 – Hannah, PTA)

Q: I was asked to be on the restraint reduction committee in our facility and need some clarification. If a resident’s bed is against the wall, is this automatically a restraint? Does it make a difference if the resident couldn’t get out of bed even it was not against the wall? What about a “low bed?”

Answer:

(February 2016 – Laurie, PT)

Q: On days when PT is out or off, OT is assigned more minutes for treatment to make up the difference. I was told this is fraud. Is this true or is it just poor practice?

Answer:

(January 2016 – Kevin,PT, RAC-CT)

Q: If a resident receives less than 15 minutes of therapy on a day, this does not count as a “day” on the MDS, but do the minutes get counted in the total located in Section O?

Answer:

(January 2016 – Kevin, PT, RAC-CT)

Q: Can you clarify if it is allowable to correct an MDS to remove a COT OMRA from a combined 14 day PPS MDS? We submitted the 14 day with a COT by accident. The RUG score went down and we want to verify if we can correct this so the 14 day is by itself. Is there a penalty?

Answer:

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