The Facility Assessment and Emergency Management Planning: The MDS Plays a Big Role

by | Jul 1, 2025 | CMS & OIG, MDS Data Elements

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What is the MDS Role in the Facility Assessment?

F838 in the State Operations Manual (SOM) provides specific information for developing a Facility Assessment that must be reviewed and updated at least annually. A well-developed facility assessment is a template that guides staff in determining what resources are necessary to care for residents competently during both day-to-day operations and in emergencies.

Accurate data collected and recorded on the MDS can be used to generate helpful reports for developing a Facility Assessment. Most EHRs have MDS-driven reports that can be utilized to identify residents with dementia, PASARR level II status, PTSD/trauma, psychiatric diagnosis, tube feeding, mechanically altered diets, dialysis, IV therapy, radiation and chemotherapy, Hospice, transmission-based precautions, oxygen and trach/vent needs, and language barriers. Additionally, any MDS that has been accepted by Centers for Medicare and Medicaid is included in reports produced from iQIES – including the Facility Characteristics Report (one of the three Package Reports), which contains facility statistical data such as gender statistics, age groups represented, ethnicity, and race among other information.

 

What is the MDS Role in Emergency Preparedness?

The SOM Appendix Z dictates that facilities must develop and maintain an emergency preparedness plan, which needs to be reviewed and updated at least annually. The annual updates must be based on and include documented facility-based and community-based risk assessments utilizing an all-hazards approach, including missing residents.

The Nurse Assessment Coordinator (NAC) or MDS Coordinator plays a crucial role in the Emergency Preparedness Plan. The NAC will be called upon to assist the administrative team in a variety of ways, including developing plans for back up or remote MDS completion during emergencies. The NAC can facilitate updating the resident’s care plans when the facility is under conditions that necessitate “shelter in place,” such as during infection outbreaks, during some natural disasters, or when an isolated area of the facility is not safe for resident living. The NAC would also focus on gathering and disseminating the most up-to-date information (including payor source) for residents in case of an evacuation or transfer.

The MDS data and reports that can be generated to support the creation of an Emergency Preparedness Plan are helpful in determining appropriate facility placement and developing agreements with those facilities for each resident – well in advance of the need for emergency evacuation. The emergency team needs to know which designated receiving facilities can appropriately care for specific residents. For example, a resident who needs specialized bariatric equipment or is dependent on a ventilator would need to be evacuated to facilities that can meet those specific requirements. A resident who wanders with dementia may need to be placed in a facility that has experience and systems in place to prevent an elopement, especially when considering the nature of emergency transfers.

 

What Happens When Residents are Relocated?

CMS has implemented rules to facilitate safe and effective care once residents have been evacuated/relocated, including temporary changes to some MDS rules for those impacted residents. The facility under evacuation due to natural disasters would contact their CMS Location (formerly known as the Regional Office), State Agency, and Medicare Administrative Contractor (MAC) for guidance. CMS has specific instructions for the evacuating and receiving facilities regarding MDS requirements in both facilities. In some situations, CMS may allow Medicare beneficiaries to access their Medicare A benefit and waive the 3-day prior hospital stay requirement (this is typically under a Section 1135 Waiver). Providers who accept evacuated residents can submit requests for consideration to obtain information available on residents’ prior MDS records by contacting the QIES Help Desk. This Help Desk can also assist with information on how to proceed if electronic MDS submission is not possible (example: the server is down or equipment has water damage).

 

Staying Prepared: Steps the NAC Can Take to Support the Facility

    • Review role responsibilities related to the NAC, the Facility Assessment, and Emergency Preparedness.
    • Ensure, at least annually, that all team members have reviewed and know when the Facility Assessment should be done; this review should also take place when there are changes in facility capacity, changes in resident population, and/or changes in staffing make up.
    • Test your back up systems to protect data collection and documentation – this may require collaboration with your IT and/or your EHR vendor.
    • Review who will manage and how data/reports/flowsheets will be pulled – including how to manage loss of power and/or loss of internet connectivity – to support ongoing data collection and distribution during emergency situations.

These are all processes that the NAC needs to have awareness and some knowledge of, with the goals being effectively supporting resident safety, ensuring transitions that are as smooth as possible, and reducing the risk for late assessments and potential payment implications.

 

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