OBRA Timing and Scheduling For the MDS 3.0

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1 Federal Requirements The AANAC OBRA Timing and Scheduling for MDS 3.0 module includes content as defined in the Long-Term Care Facility Resident Assessment Instrument User s Manual and CMS federal requirements and does not include state-specific criteria that may be required in some states Contact state agency, state RAI coordinator for additional state-specific requirements OBRA Timing and Scheduling for the MDS AANAC AANAC v3_10_14 2 Objectives Introduction to OBRA Discuss requirements for scheduling and timing of OBRA-required MDS assessments. Identify appropriate use of the discharge assessments and entry records. State the criteria for completing the Significant Change in Status Assessment. Discuss correct use of the Significant Correction assessments. Identify criteria and timing issues related to Section X, the Correction Request. Omnibus Budget Reconciliation Act of 1987 (OBRA 87) Dramatically changed the way Nursing Facilities approached resident care, radically modifying nursing home regulations and the survey process Established requirement for a nationwide, comprehensive, standardized, reproducible assessment of each resident s functional status. 3 4 Comprehensive Assessment: The RAI Process The RAI is a comprehensive assessment that consists of three major sections. The Minimum Data Set (MDS): Screening tool designed to begin the process of evaluating the resident s functional status Care Area Assessments (CAAs): Further, indepth evaluations of 20 specific functional areas Care plan: Working action plan developed based on the CAA results Includes other problems, strengths, needs also The RAI Process Per OBRA 87, residents must be clinically assessed using the MDS: Within 14 days of admission Quarterly Annually When a significant change in status occurs When an uncorrected significant error is identified in a previously completed MDS AANAC All Rights Reserved 1

2 Key Concepts: Z0400 KEY CONCEPTS Assessment Signature and Dates Signatures of individuals who completed any items or sections of the item set and dates of completion Note that interview items must be completed prior to or on ARD; therefore date at Z0400 for these items will be earlier than other items coded Attests to accuracy RN Assessment Coordinator (RNAC) signs and dates only if he or she completed portions of item set 7 8 Key Concepts: Z0500 Key Concepts: Z0500 Z0500A: Signature of RNAC certifying completion of the assessment Z0500B: The date of completion of the assessment through Z0400 This is the date the RNAC signed the assessment at Z0500A Completion at Z0500B must be no later than 14 days after the ARD at A2300 except: Admission Assessment must be no later than 14th day of resident s stay Significant Change and Significant Correction Assessments must be no later than 14th day after determining need for Significant Change in Status Assessment or Significant Correction Assessment Discharge Assessments Discharge date + 14 days Entry Tracking Record Entry date + 7 calendar days Death in Facility Record Discharge date (death) + 7 calendar days 9 10 Key Concepts: V0200 Key Concepts: V0200 V0200B1: Signature and date of RN Coordinator for CAA process V0200B2: Date of completion of CAAs Must not be earlier than the date of MDS completion at Z0500B Completion at V0200B2 has the same deadlines we just looked at for MDS completion at Z0500B MDS completion and CAA completion don t have to be on the same day CAA completion should never be prior to MDS completion AANAC All Rights Reserved 2

3 Key Concepts: V0200C Signature (V0200C1) and date (V0200C2) of person completing care planning decision This is date of care plan completion Must be completed within 7 days of CAA completion (V0200B2) Any member of the care planning team can sign at V0200C1 it need not been an RN Key Concepts: ARD Assessment Reference Date (ARD) (A2300) End point in time for observation of all items with a look-back period for the particular assessment Different MDS sections have different observation periods All end on the same day Sets common observation period for all disciplines Key Concepts: ARD A2300 Assessment Reference Date Because it sets the observation period, the ARD determines care and services captured on the MDS The observation period consists of consecutive days, including weekends and holidays ARD must be set timely to ensure assessments are completed timely Key Concept: Look-Back Period ARD FAQ 7 days unless otherwise specified Look-back period ends at midnight on the ARD Anything that occurs before or after the lookback period is not coded on the MDS Q: Can I set the ARD for the day of admission? A: It wouldn't be practical. Because very few items permit using preadmission information for MDS coding, setting the ARD so that almost the entire look-back period covers the preadmission time period would not be useful AANAC All Rights Reserved 3

4 ARD FAQs Q: Can I complete an assessment on the ARD? A: While technically allowed, this is not a good practice because observation of the resident must extend through midnight the night of the ARD (unless the ARD is also the day of discharge or death). Submission Encode in computer within 7 days of completion Transmission within 14 days of final completion or event date Comprehensive assessments: Transmit within 14 days of care plan completion (V0200C2) All other OBRA assessments: Transmit within 14 days of MDS completion (Z0500B) Discharge assessments: Transmit within 14 days of MDS completion (Z0500B) Death in Facility records: Transmit within 14 days of death (A2000) Entry records: Transmit within 14 days of entry (A1600) OBRA Types of Assessments KEY CONCEPTS Types of Assessments OBRA Reason for Assessment: A0310A 01: Admission assessment 02: Quarterly review assessment 03: Annual assessment 04: Significant Change in Status Assessment () 05: Significant Correction to Prior Comprehensive Assessment (SCPA) 06: Significant Correction to Prior Quarterly Assessment (SCQA) MDS Assessment Item Sets MDS Assessment Item Sets 10 Item sets, depending on reason for assessment Comprehensive Item Set (NC) Quarterly Item Set (NQ) PPS Item Set (NP) SOT OMRA (NS) SOT OMRA and Discharge Item Set (NSD) 10 item sets, depending on reason for assessment EOT OMRA Item Set (NO) Includes Change of Therapy (COT) OMRA Resumption of Therapy (EOT-R) items at O0450A & O0450B included on EOT Item Set EOT OMRA and Discharge Item Set (NOD) Discharge Item Set (ND) Tracking Item Set (NT) Inactivation Request Item Set (XX) Set of Items active on request to inactive a record in MDS QIES ASAP system AANAC All Rights Reserved 4

5 Timing of Future OBRA-Required Assessments Admission Quarterly Quarterly Quarterly Annual Admission Assessment First time in the facility or Was in this facility previously and returned after discharge when OBRA admission assessment wasn t completed or Was admitted to this facility previously and returned after discharge return not anticipated or Was admitted to this facility previously, was discharged return anticipated, and returned > 30 days after discharge Admission Assessment Timeline Admission Assessment Timeline Day of admission counts as day one All sections must be completed by the end of day 14 Must be signed off by RNAC at V0200B2 no later than day 14 If discharged before end of day 14, Admission assessment not required Z Dates team members completed their sections, no later than day 14 and no later than the date of MDS completion at Z0500B Z0500B - MDS completion, must be on or after the latest date in Z0400 and no later than day 14 V0200B2 - CAA completion, must be on or after MDS completion (Z0500B) and no later than day 14 V0200C2 - Care plan completion, must be on or after CAA completion (V0200B2) but no later than 7 days after CAA completion Admission Assessment Admission Assessment FAQ 2 choices if resident admitted to hospital while initial Admission assessment is in progress 1. Complete the assessment that already was started CAA completion must be by the end of day 14 of the original admission, using only information pertaining to that stay 2. Start a new assessment using a new ARD based on the readmission date (A1600) CAA completion must be by the end of day 14 of the readmission Q: After living in our nursing home for three years, Mr. Brown went to the hospital and was discharged return anticipated. Mr. Brown returned 10 days later. Do I need to complete an Admission assessment on him? A: No. Since he would have been Discharged- Return Anticipated and returned within 30 days of discharge, only a Reentry Tracking is required AANAC All Rights Reserved 5

6 Admission Assessment FAQ Admission Assessment FAQ Q: A long-term resident went to the hospital for two weeks. Her family chose not to hold the bed. Now that she has returned to our facility, is an Admission assessment required? A: No, because she would have been Discharged- Return Anticipated and returned within 30 days. Bed-hold status is not relevant to this issue. Q: After spending a month in our facility, Mrs. White went home. The family was not able to take proper care of her, and they brought her back the next day. Do we need to do a new Admission assessment? A: Yes. When a resident is discharged to home, the discharge assessment is a Return-Not Anticipated. Thus, on her return, a new Admission assessment is required Summary Of Requirements Annual Assessment Annual Assessment A0310A = 03 Must be completed at least once every 366 days Any comprehensive assessment can meet this requirement Annual assessment Significant Change in Status Assessment Significant Correction to a Prior Comprehensive Assessment Annual Assessment Annual Assessment Timeline May be replaced by an unscheduled comprehensive assessment: Significant Change in Status Significant Correction to Prior Comprehensive Annual Quarterly Quarterly Quarterly Quarterly Annual 92 Days: ARD of to ARD of next Quarterly 366 Days: ARD of to ARD of next Annual Relationship to previous assessments ARD can be no later than 366 days after ARD of last comprehensive assessment (ARD days) ARD can be no later than 92 days after ARD of last Quarterly assessment (ARD + 92 days) Z0400 The dates of team member completions, can be no later than 14 days after ARD (A2300) V0200B2 The dates of the Care Area Assessment completion, must be no more than 14 days after the ARD (A2300) AANAC All Rights Reserved 6

7 Annual Assessment Timeline Z0500B - Must be on or after the latest date in Z0400 and no later than 14 days after ARD (A2300) V0200B2 - CAA completion, must be on or after Z0500B and no later than 14 days after ARD (A2300) V0200C2 - Care plan completion, must be on or after V0200B2 but no later than 7 days after the date at V0200B2 Annual Assessment FAQ Q: Do I count from the date at A2300 (ARD), Z0500B (MDS completion), or V0200C2 (care plan completion) to determine when the Annual assessment it due? A: The 366-day count is from the ARD of the previous comprehensive and 92 days from the prior Quarterly assessment ARD Annual Assessment FAQ Annual Assessment FAQ Q: What if the resident is in the hospital when the Annual assessment comes due? A: You have 14 days after his or her return to complete any assessment that came due while the resident was out of the facility in the hospital. Q: I got off schedule, and now I have a Quarterly and an Annual assessment both due. What should I do? A: Complete the Annual assessment, and it will take the place of the Quarterly. The Annual assessment is a comprehensive assessment, and it's always okay to do more than what's required, but never less than what's required Summary Of Requirements Quarterly Assessment Quarterly Assessment A0310A = 02 Required at least once every 92 days Quarterly item set is standardized States have the option to add state-specific Section S States also may include the Optional Resident Items (included on the Comprehensive item set), which are not included in NQ item set AANAC All Rights Reserved 7

8 Quarterly Assessment Comprehensive assessment always can take place of Quarterly Annual assessment Significant Change in Status Assessment Significant Correction to Prior Comprehensive Assessment Quarterly Assessment Timeline ARD (A2300) - no later than 92 days after the ARD of previously completed OBRA assessment Z team completion dates, no later than 14 days after the ARD (A2300) Z0500B RN signature date, no later than 14 days after the ARD (A2300) Z0500B RN signature date, on or after the latest Z0400 date and no later than 14 days after the ARD (A2300) Quarterly Assessment FAQ Summary of Requirements Q: Mr. Gray is currently on Medicare. Do I still need to do his Quarterly assessment? A: Yes. The Medicare assessments are separate from the OBRA assessments. The OBRA assessments must still be completed for Medicare residents. Significant Change in Status Assessment () A0310A = Required when resident status meets criteria Admission assessment must be in QIES ASAP system before will be accepted Determine based on comparing current status to most recent Comprehensive assessment and any subsequent Quarterly assessments Significant change in status = decline or improvement in resident's status that: Will not normally resolve itself without intervention by staff or by implementing standard disease-related clinical interventions Does not return to baseline within 14 days Has an impact on more than one area of the resident's health status; and Requires interdisciplinary review or revision of the care plan, or both AANAC All Rights Reserved 8

9 If there is only one change, staff may still decide that the resident would benefit from an Nursing home staff must document a rationale, in the resident s medical record, for completing the that does not meet the criteria for completion SIGNIFICANT CHANGE IN STATUS ASSESSMENT () Examples (This is not an exhaustive list) Decline in 2 or more of the following: ADL physical functioning in which a resident is newly coded as 3, 4 or 8 (Extensive assistance, Total dependence, Activity did not occur) since last assessment in Section G Increase in the number of areas where Behavioral Symptoms are coded as being present and/or the frequency of a symptom increases for items in Section E Resident s decision-making changes Decline (continued) Incontinence pattern changes or there was placement of an indwelling catheter Emergence of an unplanned weight loss problem (5 percent change in 30 days or 10 percent change in 180 days) Begin to use trunk restraint or a chair that prevents rising when it was not used before Presence of a resident mood item not previously report by the resident or staff and/or an increase in the symptom frequency (PHQ- 9) Decline (continued) Emergence of a condition or disease in which a facility judges a resident to be unstable Emergence of a pressure ulcer at Stage II or higher, where no ulcers were previously present at Stage II or higher Overall deterioration of resident s condition; resident receives more support (for example, in ADLs or decision-making) Improvement Any improvement in ADL physical functioning areas where a resident is newly coded as Independent, Supervision or Limited assistance since last assessment Decrease in the number of areas where Behavioral Symptoms are coded as being present and/or frequency of a symptom decreases Resident s decision-making improves Resident s incontinence pattern changes Overall improvement in resident s condition AANAC All Rights Reserved 9

10 Terminal Residents not required if decline is expected course of the terminal disease process If a terminally ill resident experiences a new onset of symptoms or a condition that is not part of the expected course of deterioration, and the criteria are met for an, an is required and Hospice Services An is required to be performed when a terminally ill resident enrolls in a hospice program and remains a resident of the nursing facility Must be completed regardless of whether an assessment was recently conducted on the resident ARD must be within 14 days from the effective date of hospice If resident is admitted on hospice benefit, the facility should complete the Admission assessment and capture Hospice Completing an Admission assessment followed by an is not required unless the resident elects Hospice AFTER the ARD of the Admission assessment and Hospice Services: An is required to be performed when a resident receiving hospice services discontinues those services (revocation of hospice services) The ARD must be within 14 days of one of the following: The effective date of the hospice revocation The expiration date of the certification of terminal illness The date of the physician s or medical director s order stating resident is no longer terminally ill not required under the following circumstances: Short-term acute illness from which the IDT expects full recovery Well-established, predictable cyclical patterns of clinical signs and symptoms associated with previously diagnosed conditions (bipolar disease, etc.) Resident continues to make steady progress under current course of care Resident has stabilized and discharge is expected in the immediate future timeline ARD must be within 14 days of determining the need for an V0200B2 (CAA completion) and Z0500B (MDS completion) must be no later than 14 days after determining that criteria for are met If criteria are determined to be met in process of completing Quarterly or Annual assessment, code and complete the assessment as a comprehensive instead After IDT has determined that a resident meets significant change guidelines, the nursing home should document the initial identification of a significant change in the resident s status in the progress notes AANAC All Rights Reserved 10

11 Possible Need for Level II PASRR Screening Preadmission Screening and Resident Review (PASRR) Identifies individuals with mental illness, intellectual disability, or a condition related intellectual disability that may require special services When a comprehensive assessment is being completed for a resident known or suspected to have one of the following: 1. Mental illness 2. Intellectual Disability 3. Condition related to intellectual disability A referral to the state mental health or intellectual disability/dd authority for a possible Level II PASRR evaluation must promptly occur Summary of Requirements Significant Correction to Prior Comprehensive Assessment (SCPA) A0310A = SCPA SCPA Required when an uncorrected significant error is discovered in a prior comprehensive assessment Error is significant when the clinical status is misrepresented It is uncorrected if a subsequent assessment with the correct information has not been submitted Never appropriate for a PPS-only assessment use modification process alone for these errors Nursing Homes should document the initial identification of a significant error in an assessment in the progress note Two-Step Process: Modify erroneous record Or correct erroneous data if not yet accepted into QIES ASAP system Set new, current ARD for SCPA and complete new assessment Must be completed within 14 days of determination that significant error not corrected by subsequent assessments has occurred Only used for assessments that have an OBRA reason for assessment MDS Correction Policy SCPA FAQ Complete a Section X Correction Request for modification of the original erroneous record Correct the items that were in error Submit the entire corrected original assessment (not just the corrected items), retaining original ARD and completion dates, along with the modification request Q: We entered the wrong birthday for a resident. Should we complete a correction assessment to change it? A: No, since an incorrect birth date does not misrepresent the resident's clinical status, a correction assessment would not be required. Correct the error by submitting a Correction Request Form for modification of the record, in conjunction with a copy of the corrected assessment AANAC All Rights Reserved 11

12 Summary of Requirements Significant Correction to Prior Quarterly Assessment Significant Correction to Prior Quarterly Assessment A0310A = 06 Completed when an uncorrected significant error is identified in a prior Quarterly assessment A significant error is one that misrepresents the resident s clinical status Significant Correction to Prior Quarterly Assessment Completed when a significant, uncorrected error is found in a Quarterly assessment. Same process as SCPA Modify erroneous Quarterly assessment. Set a current ARD and complete an SCQA ENTRY AND DISCHARGE REPORTING REQUIREMENTS Entry Tracking Record Entry Tracking Record Coded as either an Admission or Reentry in A1700 First item set completed for all residents Must be completed every time any resident is admitted or readmitted Must be completed within 7 days of entry date (A1600) Must be submitted no later than 14 days after entry date (entry date + 14 days) May not be combined with any other assessment Admission (A1700=1) Admitted for first time or Was in this facility previously and returned after a discharge when the OBRA Admission assessment was not completed or Was in this facility previously and returned after a discharge return not anticipated or Was in this facility previously, discharged return anticipated, and returned > 30 days after discharge AANAC All Rights Reserved 12

13 Entry Tracking Record Reentry (A1700=2) Required every time a person is readmitted to a nursing home when Resident was previously admitted to this nursing home and An OBRA Admission assessment was completed and The resident was discharged return anticipated and The resident returned within 30 days of discharge Discharge Assessments Must be completed any time: Resident is discharged from the facility, or Admitted to acute hospital, or Hospital observation stay exceeds 24 hours Applies: Regardless of facility s policy for opening and closing of records Regardless of bed-hold status May be combined with other assessments Discharge Assessments Not required when the resident: Is on temporary home visit of at least one night Is on therapeutic leave of at least one night Is in a hospital observational stay of < 24 hours and is not admitted to the hospital ARD must equal the discharge date (A2000) Discharged Return Not Anticipated Discharge Return Not Anticipated (A0310F = 10) Required when resident is discharged and not expected to return to the facility within 30 days Correct MDS record when the resident is discharged to: Home, lower level of care, another nursing home Completion (Z0500B) must be within 14 days of the discharge date (A days) Discharged Return Anticipated Discharge Return Anticipated (A0310F = 11) Required when resident is discharged and expected to return within 30-days Discharge to inpatient hospital admission Respite stay when resident comes in and out on relatively frequent basis and reentry can be expected within 30 days Z0500B must be within 14 days of discharge date (A days) Discharge Assessments Unplanned Discharges Unplanned discharges: If completing a stand-alone Discharge assessment no interviews required. Complete staff assessment of mental status only If combining Discharge with other assessment type, use with available information If scripted interviews were not completed, code respective gateway items (C0100, D0100, F0300 and J0200) no, skip resident interview, complete staff assessment as much as possible Enter - only when unable to determine response to an item AANAC All Rights Reserved 13

14 Determining 30 Day Criteria In determining if a resident returned to the facility within 30 days, the day of discharge is not counted in the 30 days. Example: A resident discharged on December 1 would need to return to the facility by December 31 Death in Facility Record Death in Facility Record (A0310F = 12) Completed when the resident dies in the facility or when on LOA Must be completed within 7 days after resident s death (A2000, discharge date = date of death) Must be submitted within 14 days after resident s death (A days) May not be combined with any other assessment Discharge and Reentry FAQ Discharge and Reentry FAQ Q: What happens if the resident returns after a discharge return not anticipated? A: You must complete a new Admission assessment and begin a new schedule. Q: If a resident is transported to the ER and is gone overnight but is not admitted to the hospital, what assessment(s) should be completed? A: No additional assessments are required since the resident is still in an admitted status in the Nursing Home Discharge and Reentry FAQ Resources Q: What should I do if I learn that a resident who was discharged return anticipated to the hospital goes to a different facility when he is discharged from the hospital? A: Once you learn that a resident has in fact been admitted to another facility or has expired and will not be returning to your facility, there is no federal requirement to inactivate the resident's record nor to complete another Discharge assessment. Contact State Agency/State RAI Coordinator for specific state requirements. AANAC: QIES Technical Support MDS 3.0 Information: https://www.qtso.com/mds30.html Centers for Medicare & Medicaid Services, Long- Term Care Facility Resident Assessment Instrument User s Manual: AANAC All Rights Reserved 14

15 QUESTIONS AANAC All Rights Reserved 15

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