Effective October 1, 2023, several resident interviews were added to or updated on the MDS. Interview items in Section A and changes to the interviews in Section D, J, and Q have been implemented. Each of the interviews can be a great steppingstone in your path to creating a plan of care that puts each resident’s needs and preferences in focus and allows staff to support individual resident goals. Interviews in Sections C and D can affect PDPM scores and increase reimbursement based on responses (incomplete/dashed items may translate to decreased current PDPM scoring). Interviews in Sections A, B, C, D, J, and Q can also impact future Medicare reimbursement, based on whether these items are completed or dashed (incomplete).
According to the RAI, “Residents should be the primary source of information for resident assessment items. Should the resident not be able to participate in the assessment, the resident’s family, significant other, and guardian or legally authorized representative should be consulted.” Interviews in Section A (race and ethnicity) can be answered based on medical records only in certain circumstances.
Section B0700 – Makes Self Understood
Although this is not an interview item, NACs and other members of the IDT who complete interviews and/or code their interview items on the MDS should be aware that responses to Section B0700 have direct bearing on interviews, and vice versa. The RAI coding Tips and Special Populations instructions indicate “This item cannot be coded as Rarely/Never Understood if the resident completed any of the resident interviews, as the interviews are conducted during the look-back period for this item and should be factored in when determining the residents’ ability to make self understood during the entire 7-day look-back period.” If the resident is at least sometimes understood, then interviews should be attempted.
Consider your resident’s ability to answer interview questions. Do you need to get an interpreter to help complete interviews? Have you ensured the resident can hear and/or see you when interviews are being done? Have you considered using cue cards to increase nonverbal and/or hearing impaired resident participation? Is the interview setting calm and quiet, and have you allotted time for resident responses that may be slow?
How do resident interviews affect future reimbursement?
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- There is a 2-year delay between data collection and the affected FY (fiscal year) application of the Annual Payment Update (APU). For example, data collected in CY (calendar year) 2023 will be used in support of the FY 2025 APU.
- APU determination is based on submission of the standardized resident assessment data elements and the data used to calculate the QMs (Quality Measures), not on the QMs themselves.
- The FY 2026 SNF QRP APU determination spans two versions of the MDS.
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- MDS 3.0 v.1.18.11 October 1, 2023 CY Q1 – Q3 2024 (January – September 2024)
- MDS 3.0 v.1.19.1 October 1, 2024 CY Q4 2024 (October – December 2024)
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- SNF APU MDS Assessment Data threshold – CMS states that “90% of data submitted to iQIES must contain 100% of the required measures and standardized patient assessment data.” This means that missing information (dashed items on the MDS) effective October 1, 2023 through September 2024 can affect your Medicare reimbursement in 2026.
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Which interview can be found on which assessment?
Currently there are 13 interview sections, some with subsections based on individual response. These interviews should be conducted on or before the ARD, within the 7-day lookback period.
A1005 Ethnicity – on every tracking and MDS form.
A1010 Race – on every tracking and MDS form.
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- “If the resident is unable to respond, the assessor may ask a family member, significant other, and/or guardian/legally authorized representative. In the cases where the resident is unable to respond and the response is determined via family, significant other, or legally authorized representative input or medical record documentation, check all boxes that apply, including X. Resident unable to respond.”
- “Only use the medical record to code A1005 Ethnicity and A1010 Race if the resident is unable to respond and no family member, significant other, and/or guardian/legally authorized representative provides a response for these items.”
- “When the resident declines to respond, code only Y. Resident declines to respond. When the resident declines to respond, do not code based on other resources (family, significant other, or legally authorized representative or medical records).
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A1110 Language – on every MDS form.
A1250 Transportation – on PPS assessments (Medicare). Incomplete (dashed) items will be counted toward APU changes.
B1300 Health Literacy – on PPS assessments (Medicare). Incomplete (dashed) items will be counted toward APU changes.
C0200 – C0400 Brief Interview for Mental Status (BIMS) – on every assessment except unplanned OBRA discharges. Incomplete (dashed) items will be counted toward APU changes; however, unplanned PPS discharge interview items may be dashed without penalty. Regular review of RAI coding instructions is recommended due to the impact this interview has on care planning and reimbursement.
D0150 Mood (PHQ-2 to 9) – on every MDS except unplanned OBRA discharges. Incomplete (dashed) items will be counted toward APU changes; however, unplanned PPS discharge interview items may be dashed without penalty. Regular review of RAI coding instructions is recommended due to the impact this interview has on care planning and reimbursement.
D0700 Social Isolation – on every MDS except unplanned discharges. Incomplete (dashed) items will be counted toward APU changes; however, unplanned PPS discharge interview items may be dashed without penalty.
F0400 Interview for Daily Preferences – on comprehensive MDS.
J0300 – J0600 Pain Assessment – on every MDS except unplanned discharges and IPAs. Incomplete (dashed) items will be counted toward APU changes; however, unplanned PPS discharge interview items may be dashed without penalty. If the resident was interviewed but could not complete the assessment, the staff interview should be completed.
Q0110 Participation and Assessment and Goal Setting – interviews on every MDS except discharges and IPAs. If the resident participated in ANY interview items, then code Q0110A Yes.
Q0310 Resident’s Overall Goal – interviews on Admission assessments. “The response to this item must reflect the resident’s perspective if they are able to express it. If the resident is not able to participate in the interview or communicate their preferences clearly, then information can be obtained from family, a significant other, or other legal representative.”
Q0500 Return to Community – interviews on Admission, Quarterly, and Annual Assessments. If the resident or representative has indicated they only want to review this question on comprehensive assessments, this should be noted somewhere in the record, and only asked again on comprehensive assessments. The Care Plan is a suitable place to note resident/representative preferences for this item.
How can your facility improve capturing interview items?
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- Assign staff to be responsible for completing interviews and ensure alternate staff are available to complete interviews if the regular staff is not available.
- Ensure your staff know when the ARDs are set, and update staff when ARDs change.
- Encourage staff to review interview coding instructions in the RAI manual periodically to ensure interviews are conducted correctly. Consider implementing interview competency checks.
- Interviews can be coded directly into the MDS and do not require additional supporting documentation if they are completed on or before the ARD.
- If your staff completes assessments/observations with interviews embedded, ensure your interview tools are updated to reflect the changes that were implemented October 1, 2023.
- If interviews are conducted on paper to be coded after the ARD, ensure the paper form is uploaded into the EHR to provide supporting documentation.
- Review validation reports to determine if incomplete interview items (dashed) will be affecting payment. Warnings for potential payment reduction are listed under -3897 and -=3908.
- Create a PIP to reduce missed interviews.
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