Some skilled nursing facilities (SNFs) are concerned about accurate payment when a resident unexpectedly discharges and the Brief Interview for Mental Status (BIMS) has not yet been completed.
However, they should be just as concerned about the PHQ-9.

The PHQ-9 identifies depressive symptoms to be captured on the MDS. The interview follows the same basic rules as the BIMS.

  • Both interviews should be conducted, preferably on the day of or the day before the ARD.
  • The provider cannot complete the Staff Assessment of Resident Mood if the resident interview should have been conducted but was not done. For example, A resident is admitted, and the 5- day ARD is set for day 8. The social worker would not be conducting the PHQ-9 interview until day 7 or 8, but what happens when the resident is discharged unexpectedly on day 5?
  • CMS does not allow the staff assessment to be done for an interviewable resident when an unplanned discharge occurs before the PHQ-9 is completed. That means the payment will automatically default into non-depressive case-mix classification in the nursing component, which could result in a significant loss.

Without the BIMS, there is a potential loss of approximately $15 per day. While, without the PHQ-9, there is a potential loss of approximately $40 or more a day, depending on the local base rate.

With the advent of PDPM, some facilities began completing the BIMS interview upon admission to use in case of an unexpected discharge. The facility should consider adding the PHQ-9 to the BIMS for admission assessments

Interviewing on the day of admission may be even more critical because:

  • CMS makes no provision for doing the staff assessment instead of the PHQ-9 for unexpected discharges the way it does for the BIMS.
  • From a clinical standpoint, the clinical team being aware of depressive symptoms upon admission can trigger earlier treatment and person-centered care planning approaches to help manage the depression.

Keep in mind the RAI manual states the BIMS and PHQ-9 interview is to be completed the day before or of the ARD. If these interviews are completed upon admission, they should not be used for an assessment with a later date. For example, an assessment with an ARD set for day 8 could not use interviews from the day of admission.

The best practice is to conduct another interview on the day before or the day of the ARD.  Following this practice ensures an accurate MDS assessment and accurate reimbursement.

More Resources

For the BIMS and PHQ-9 tools, see: https://mdsconsultants.wpengine.com/minimum-data-set-forms/

For more information:  https://downloads.cms.gov/files/mds-3.0-rai-manual-v1.17.1_october_2019.pdf

Explore More Posts from MDS Consultants

Get ready for October 1

Transportation – New Item A1250

This post is part of the MDS 2023 Countdown series.  Disclaimer. Current as of October 1, 2023 What You Can Expect to See An additional item we will see in the upcoming MDS 3.0 v.1.18.11 in October 2023 is A1250 - Transportation. This is included in a new subset of...

New 3-day Lookbacks | Assessment Periods

This post is part of the MDS 2023 Countdown series.  Disclaimer. Current as of March 24, 2023 What You Can Expect to See New 3-day lookback/assessment periods are coming to the MDS world. There are different sections of the MDS that the Nurse Assessment Coordinators...

New Pain Interview in Section J

This post is part of the MDS 2023 Countdown series.  Disclaimer. Current as of February 22, 2023 What You Can Expect to See The most noticeable changes to Section J are evident in the pain interview, specifically questions J0510, J0520 and J0530. The RAI Manual has...

Section B – Hearing, Speech and Vision Changes

This post is part of the MDS 2023 Countdown series.  Disclaimer. Current as of October 1, 2023 What You Can Expect to See Section B on the MDS is a component of the Standardized Patient Assessment Data Elements (SPADEs), which is utilized across post-acute care...

Race and Ethnicity – Changes in Section A

This post is part of the MDS 2023 Countdown series.  Disclaimer. Current as of October 1, 2023 What You Can Expect to See Section A, Identification Information for Race/Ethnicity has expanded. One of the major changes is the deletion of section A1000 Race/Ethnicity....

Read more on Toolbox Essentials

Focused Infection Control Surveys and Directed Plan of Correction

It's a dreary Monday morning, and the state surveyors walk into your facility to conduct a Focused Infection Control survey. You and your team have been trying your hardest to comply with infection control procedures throughout the pandemic. At the end of the survey,...

New Advanced Beneficiary Notice

Is your facility using the proper ABN form? The Centers for Medicare & Medicaid Services (CMS) recently updated the Advanced Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131. The new ABN will be mandatory for use on 1/1/2021, but the new form can be...

Covid-19 and Skilled Status

In late June, CMS addressed two issues and posted MDS 3.0 Final Item Sets (V1.17.2).  The two edits were changes to facilitate the calculation of Patient-Driven Payment Model payment codes on OBRA assessments for states that wish to have this calculation performed. ...

MDS in the Emergency Preparedness Plan

The COVID-19 pandemic has highlighted the need for skilled nursing facilities to have an effective Emergency Preparedness Plan - one that includes sheltering-in-place. The Centers for Medicare and Medicaid Final Rule requires that participating providers have an...

COVID-19 Resources

COVID-19 (coronavirus) Tools In this difficult time, MDS Consultants is here for you with reimbursement guidance and can help with MDS completions when needed. Our team keeps an up-to-date list of links and resources at MDS Expert  COVID-19 (coronavirus) Updates Novel...

MORE from MDS Experts

Schizophrenia Diagnosis Audits

On January 18th, 2023, CMS announced they will be conducting off-site audits in nursing homes for assessment accuracy and coding of residents with a diagnosis of Schizophrenia. Along with auditing for appropriate diagnosis, the audits will review appropriate use of...

OSA or PDPM? A State-Level Decision

As of Oct. 1, 2023, the Centers for Medicare & Medicaid Services (CMS) has retired the A0300 Optional State Assessment (OSA) from the federally required MDS 3.0 v1.18.11 that is submitted by nursing facilities. The OSA is now a separate optional MDS assessment...

The Physician and “I”

The physician’s role in the nursing facility is essential to delivering skilled, quality care for Skilled and Long-Term Care residents. Physicians are our lead in providing clinical decision making and properly defining, clarifying, and verifying diagnoses. Only the...

Coding UTIs on the MDS 3.0

Urinary Tract Infections (UTIs) are a commonly miscoded data element on the MDS. Are you over coding UTIs? Are you not coding them at all? Should you? Shouldn’t you? The MDS has historically left data collectors asking themselves these questions. What happens if I do...

Achieving Accurate ADLs with the OSA

Section G of the MDS 3.0 was retired October 1, 2023, yet the MDS nurse may still need to use the knowledge of accurately coding ADLs with an assessment called the Optional State Assessment (OSA).  State-Optioned OSA Although the option to choose an OSA from the...

Webinars & Training

Grow your knowledge with our MDS education

MDS Guides & Forms

Exclusive resources & tools we use every day

Ask an Expert Forum

Members can get 1:1 advice from our MDS experts

Let's Meet in Person

Get more info on our training & conference schedule

News for MDS Experts

Browse our blog & get news alerts on MDS changes

MDS Completion

Get your MDS' done ASAP with short-term, expert help

Remote Floater

Fill gaps on your team when & where you need

Case Mix Index

Improve your complex case mix calculations

MDS System Mgt

Best practices for MDS schedules & workflow

+ More Services

Get help on PDPM, ICD-10, quality, schizoph. audits ++