Updates for Long-Term Care from the Train-the-Trainer Conference

The Minimum Data Set, Version 3.0 (MDS 3.0) Train-the-Trainer conference held in Baltimore April 13-15 provided attendees with a wealth of information regarding the new long-term care assessment tool, which will be implemented in October.

During the conference, officials from the Center for Medicare & Medicaid Services (CMS) and other speakers provided an overview of the MDS 3.0, step-by-step coding explanations for multiple sections, and interesting information regarding the delay of Resource Utilization Group, Version Four (RUG-IV) and changes to the MDS 3.0 and Resident Assessment Instrument (RAI) User's Manual.

Some of the major updates include the following:

• If the partial RUG-IV delay is implemented as outlined in healthcare reform, CMS will have to do some work on the back-end of things to transform the RUG-IV grouper determined by the MDS 3.0 back into a RUG-III grouper for payment. CMS officials said that the modified system would not be in place for the October implementation of the MDS 3.0 and may not be ready until the end of the year. They did not give a definitive answer about how payments to facilities will be affected by this. When CMS figures out a transition approach and what tool will be used during this time, they will inform providers. However, CMS officials are working to have RUG-IV implemented on October 1, 2010 (as originally planned) and seemed to think there is still a chance that this will occur.
• The timeline to change the items on the MDS 3.0 to be implemented in October has already passed, so any changes to the item sets will just be to clarify the language, not to the actual items. However, CMS said there will be revisions to the item sets in early or mid 2011.
• An updated version of the RAI User's Manual is expected for late May or early June. CMS will release the sections as they are finished, rather than hold the sections until the entire revised manual is ready. The revisions will mostly be to clarify the coding and assessment rules.
• After the October implementation of the MDS 3.0, nursing facilities will not be able to access the Quality Measure and Quality Indicator (QM/QI) reports for a number of months.
• A new draft of Appendix P and PP of the State Operations Manual is expected to be released in early August. Some of the changes included in these appendices will address modifications to the survey process while the QM/QI reports are not available.
• The updated RAI User's Manual will change the MDS transmission date for the admission, annual, significant change in status, and significant correction to prior comprehensive assessments. The RAI User's Manual released in January lists the transmission date for these assessments as no later than the MDS/Care Area Assessment (CAA) completion date + 14 days. The revised manual will change the transmission date for these assessments to be no later than the care plan completion date + 14 days. The care plan must be completed within seven calendar days after the MDS and CAA completion date.
• The updated RAI User's Manual will change the timeframe to conduct the Resident Mood Interview (PHQ-9). Although preferred, the PHQ-9 interview will no longer be required to be conducted the day before or the day of the assessment reference date (ARD). CMS officials did recommend that the resident interview be conducted as close to the ARD as possible.

There is still a lot up in the air and CMS seems to be taking all comments into consideration as they make their revisions to the RAI User's Manual. Stay tuned for more information and updates as we approach the October 1 implementation date.