Since 2023, there have been a multitude of changes to the Minimum Data Set 3.0 (MDS), the Skilled Nursing Facility Quality Reporting Program (SNF QRP), and the Skilled Nursing Facility Value-Based Purchasing Program (SNF VBP). While most of these changes have been incorporated into our current day-to-day processes, each year’s release of the new RAI Manual, MDS item sets, and Proposed Rule brings the potential for additional changes that providers need to be mindful of. The upcoming draft RAI Manual, v1.19.1, has not yet been issued, but based on the typical process for RAI Manual updates providers can expect the draft to be released in the near future. The draft RAI Manuals for the upcoming fiscal year are usually issued between April and June, with the final RAI Manual being published around August to September. The RAI Manual updates generally go into effect each October 1. The Centers for Medicare & Medicaid Services (CMS) has made public the final item sets for the MDS 3.0 v1.19.1, which includes some notable changes occurring in Sections A, B, D, GG, I, J, N, and O. The final MDS 3.0 v1.19.1 item sets can be found here. This article aims to highlight some of these changes, as well as discuss the SNF QRP and SNF VBP updates from the FY 2025 SNF PPS Proposed Rule.
The transfer of health information items in Section A will be removed from the standalone PPS Part A Discharge (NPE) item set. This includes A2121, Provision of current reconciled medication list to subsequent provider at discharge, and A2122, Route of current reconciled medication list transmission to subsequent provider. However, these questions will remain active on a PPS Part A Discharge that is combined with an OBRA Discharge assessment. Thus, facilities must continue gathering and documenting discharge information to support the MDS coding of items A2121 and A2122 when a resident who ends their Part A services is physically discharged from the facility.
Another prominent change in the upcoming item sets includes the removal of column two in Section GG – Discharge Goals. The SNF QRP measure that required the coding of at least one self-care or mobility discharge goal was retired effective October 1, 2023. Still, the removal of this column from the MDS assessment does not eliminate the necessity for care planning functional goals for improvement or to prevent declines. Establishing functional goals for our residents is very important for care planning, especially for those residents who are receiving skilled services and for those residents who are newly entering the facility. Although we will not be coding functional goals for discharge on the MDS assessments as of October 1, 2024, we still need to evaluate, document, and monitor those goals to facilitate person-centered individualized care planning.
A new high-risk medication class, anticonvulsants, is being added to Section N0415. Because anticonvulsants are considered high-risk medications that can affect the brain and are often prescribed for mental health disorders (e.g., to assist in stabilizing mood), the addition of this item in N0415K is not surprising. CMS also addresses in the State Operations Manual, Appendix PP (F757 and F758), that anticonvulsants are a class of drugs that may increase the risk of adverse consequences. Including anticonvulsant use in the MDS assessment can assist the interdisciplinary team to pay closer attention to these medications and the potential impact they may have on their residents who are taking them.
The last noteworthy change to the MDS effective October 1, 2024, is the addition of data element O0350, Resident’s COVID-19 vaccination is up to date. This data element will be included on all item sets, with the exception of the Interim Payment Assessment (IPA) and the tracking records. Providers will want to ensure they review the coding instructions of this item when the RAI Manual is published to determine what CMS will consider as “up to date.”
Lastly, we will briefly discuss the Fiscal Year (FY) 2025 SNF PPS Proposed Rule. This proposed rule includes updates to the ICD-10-CM mappings for the Patient-Driven Payment Model (PDPM) clinical categories. Additionally, CMS is seeking feedback about a plan that is not proposed, but is under consideration, for significantly updating the comorbidity list used in the Non-Therapy Ancillary (NTA) component of PDPM. With regards to the SNF QRP, CMS is proposing the collection of four new standardized patient assessment data elements (SPADES) and revising one of the standardized patient assessment data elements in the social determinants of health (SDOH) category. The four new SDOH items include living situation, utilities, and food (two items). The SDOH item to be modified is the current transportation data element. The proposed rule also stated CMS intends to implement data validation programs for MDS-based and claims-based quality measures in the program. In FY 2024, CMS adopted two MDS-based quality measures in the SNF VBP effective with the FY 2027 program year. Fiscal Year 2025 (i.e., beginning October 1, 2024) is the first performance period for both measures – Percent of Residents Experiencing One or More Falls with Major Injury (long stay) and Discharge Function Score (short stay).
While the changes are not going to be as extensive as last year’s, with October 1 quickly approaching there are still changes we are going to see related to the RAI Manual, the SNF QRP, and the SNF VBP. RB Health Partners Inc. will continue to monitor these changes as they are published. For more information about this or other related topics, please contact Katie Slier, RN, BSN, RAC-CTA, Director of Clinical Reimbursement & Analytics at [email protected].
