New Year….Same MDS Obstacle Course

by | Jan 1, 2024 | MDS Data Elements

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As we ring in 2024, long term care professionals are still struggling to implement the October 2023 updates to the MDS. CMS is already talking about more changes in 2024, and the anticipation continues to create anxiety amongst PAC members. While the full ramifications of the 2023 updates remain to be determined, let’s recap the major changes in 2023.


What Major Changes Occurred After October 1, 2023?

The MDS 3.0 item sets v1.18.11 v6 was released along with an errata document with revisions to the MDS 3.0 User’s Manual (MDS 3.0 RAI Manual version (v)1.18.11R).

  • Section D D0100: Should Resident Mood Interview be Conducted?
    • D0100 serves as a gateway item for the Resident Mood Interview (PHQ-2 to 9) and D0500, Staff Assessment of Resident Mood (PHQ-9-OV). The assessor will complete the Staff Assessment only when D0100 is coded 0, No. The assessor does not complete the Staff Assessment based on resident performance during the Resident Mood Interview.
    • Resident refusal or unwillingness to participate in the interview would result in Item D0100 being coded 1, Yes, and code 9, No response being entered in Column 1. Symptom Presence. Assessors should proceed to Item D0700, Social Isolation in the case of resident refusal or unwillingness to participate.
  • Section D D0500: Staff Assessment of Resident Mood
    • When staff determine the resident is not able to complete the PHQ-2 to 9©interviewable (i.e., D0100 = 0, No), scripted interviews with staff who know the resident well should provide critical information for understanding mood and making care planning decisions.
  • Section O O0400: Therapies
    • Therapies with the updated item including the removal of the completion language, “Complete only when A0310B = 01 (complete O0400D2 when required by state).”

Section O0400 (Therapies) has been especially confusing since the transition. Effective 10/1/2023, O0400 was not going to require coding on OBRA MDS assessments. This came as a surprise for many providers, as it was not mentioned as one of the changes. How can we not code therapy on the MDS? CMS later clarified that therapies were going to be coded on the MDS effective 11/1/23. (Visit Errata v3.01.3 for MDS 3.0-v3.01.1 for more information.)

Not only are the changes to the MDS data elements causing providers issues, but so are problems with EMR software. Software venders are experiencing complications with the coding of the MDS in their systems and subsequent alignment with the data elements. And it’s not just one software vendor – it’s across the board. (One of the significant issues is getting an accurate HIPPS (Health Insurance Prospective Payment System) code within the EMR systems.)

These issues are, in turn, compounding difficulties for providers attempting to submit a completed MDS to iQies. Numerous error codes are flagging on MDS Validation Reports – to the point where some MDS assessments are being rejected. Providers are rightly worried they will not be in compliance with their MDS submissions. (CMS recommends that providers contact their vendors, iQies, and MACs with their questions.)


Tips from MDS Consultants

    • Review all CMS manual and document updates to ensure your facility policies and procedures relating to RAI system management are up to date.
    • Continue to ensure training is up to date for IDT team members.
    • Create a tracking system to ensure corrections are completed in a timely manner.
    • Identify a point person to stay in contact with software vendors to ensure updates are communicated to the IDT.

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