Wednesday, October 23, 2019

CMS Confirms Exploring the Possibility of Eliminating MDS Section G Items from SNF 5-Day and OBRA Assessments beginning FY 2021

Dan Ciolek

Recently AHCA has been receiving reports from members and state affiliate staff that they are hearing from state Medicaid officials and other sources that Centers for Medicare and Medicaid Services (CMS)  officials are stating that it is possible that the Minimum Data Set (MDS) Section G Activities of Daily Living (ADL) items may be eliminated from the Skilled Nursing Facility Prospective Payment System (SNF PPS) 5-Day and OBRA Comprehensive and OBRA Quarterly assessment types. 

AHCA was aware that CMS was exploring the possibility of this occurring as the concept has been discussed in recent rulemaking and technical expert panel (TEP) discussions to reduce the confusion and burden associated with two different sections of the MDS (Sections G and GG) being used to report a resident’s function, but with vastly different scoring methodologies.  No formal timelines had been discussed to date.  We were also aware that CMS had contracted with RTI to conduct a study to determine if section GG would be reliable and valid to use with long-stay residents. 

In response to an AHCA request for clarification of the status of Section GG on the MDS, CMS stated that it is true that the Agency is considering retiring Section G items from the PPS 5-Day, and OBRA assessments effective October 1, 2020 if current analysis indicates it would be appropriate to use Section GG exclusively for short and long-stay residents.  CMS sees this as reducing reporting burden.  Regardless of the decision, the MDS Optional State Assessment (OSA) would continue to include Section G items beyond October 1, 2021 for a period yet to be determined to permit other payers (some Medicaid, some VA, TRICARE, and some Medicare Advantage) to continue with RUGs or other methodologies that rely on Section G item data.

In other words, providers should be prepared that further changes to the SNF PPS and OBRA MDS assessment types related to Section G items may be implemented as early as October 1, 2020, and that at that time, the OSA will be the only MDS assessment type that will be able to generate a RUGs-based payment classification.  Typically, the first indicator of formal proposed changes to the MDS are revealed with the CMS release of draft MDS technical specifications and draft MDS Manual guidance that are posted after the new year.  AHCA will provide updates on this topic as more information becomes available.   

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