Resident Assessment Instrument (RAI)
and Minimum Data Set (MDS) Update
PDF Version
of BQA 01-041 (PDF, 17 KB)
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Date: October 22, 2001 DSL-BQA-01-041
To: Nursing Homes NH 23
From: Jan Eakins, Chief, Provider Regulation and Quality Improvement Section
cc: Susan Schroeder, Director, Bureau of Quality Assurance
The purpose of this update is to provide you with information related
to:
New SUB_REQ Field
Beginning November 26, 2001, a new field, SUB_REQ, will be a required
field on all MDS records submitted to the State MDS System. The Centers
for Medicare and Medicaid Services (CMS) has authority to collect MDS
information for all residents residing on a certified unit in a nursing
home. Some states have authority to collect MDS information for residents
on non-certified units, while other states do not have that authority. The
SUB_REQ field is being added to identify under what authority MDS records
are being submitted.
Wisconsin does not certify only certain units of a nursing home. The
entire nursing home is certified or not certified. Wisconsin nursing homes
should always code SUB_REQ as 3, the resident is on a
Medicare/Medicaid certified unit, submission of the record to the State is
required under CMS authority.
Nursing homes should contact their software vendor to ensure proper
coding of the SUB_REQ field.
Monthly Quality Indicator
Comparison Report
CMS has developed an additional MDS quality indicator report that is
now available. This report, the Monthly Quality Indicator Comparison
Report, is generated at the end of each month. The Monthly Quality
Indicator Comparison Report contains facility-level information while
conforming to privacy rules; thus States and facilities may release these
reports.
These reports can be released to:
These reports are Scheduled Reports that automatically generate
the 28th of each month. Nursing homes may obtain their reports
by accessing the State MDS Website. The reports are located in the same
area as MDS Initial Feedback Reports, MDS Final Validation Reports, and
other Scheduled Reports. Refer to the Long Term Care Facility User’s
Manual for detailed instructions for accessing MDS reports from the State
MDS System.
The attached CMS memorandum, Ref: S&C01-24
(exit DHS; PDF),
September 20, 2001, contains specific information about these reports and
guidelines for use of information by recipients.
Fall 2001 RAI/MDS Training
The Bureau of Quality Assurance will be presenting the following RAI/MDS
training programs. Detailed training information and registration
information is available on the Bulletins section of the State MDS System.
MDS AUTOMATION - Half-day conference 8:30 – 12:30 (This class is
full.)
RAI-MDS BASICS – Full day conference 8:15 – 3:45
-
Green Bay – October 24, 2001, Best Western Midway Hotel
-
Madison– October 30, 2001, Radisson Inn
ASSESSMENT/CARE PLANNING BEYOND BASIC RAI – Full day conference
8:15 – 3:45
-
Green Bay - November 29, 2001, Holiday Inn – Airport
-
Waukesha – December 4, 2001, Country Inn Hotel/Conference Center
These programs will each have space for only 75 participants. Training
brochures and registration forms are being mailed to all nursing homes. If
you need additional information, please call Leann Graffin at (608)
267-1438.
Section AA – Resident Numbers
Effective April 30, 2001, enhanced editing was applied to MDS items
AA5a, AA5b, and AA7 to ensure submission of valid values. Failure to meet
the edits will result in Fatal Record Message -29, "Invalid data
values", and will cause the record to be rejected by the State MDS
System. Listed below are the edits that are applied to these numbers:
AA5a (Social Security Number)
-
Must be 9 digits, 9 dashes (unable to determine), or 9 spaces
(blanks).
-
Cannot start with 000.
-
Cannot be 111111111, 333333333, or 123456789.
AA5b (Medicare Number)
-
The total length cannot exceed 12 and no embedded spaces or dashes
are allowed.
-
12 dashes (unable to determine) or 12 spaces (blank – not
Medicare) are acceptable.
-
If the number starts with a digit, then it is a HIC code and must
have nine digits in the first nine places.
-
In rare instances, a resident will have neither a Medicare number
nor a Social Security number. When this occurs, another type of basic
identification number (e.g., railroad retirement insurance number) may
be substituted. In such cases, a C followed by the number will be
accepted.
-
NA, C, +, N are not acceptable.
AA7 (Medicaid Number)
-
Entries containing quotes will cause a record to be rejected.
-
A valid value of + should be entered in the left-most box if the
number is pending (not "+").
-
A valid value of N should be entered in the left-most box when a
number is not applicable because the resident is not a Medicaid
recipient (not "N").
CMS Clarification for
Coding Section P4 – Devices and Restraints
The federal Centers for Medicare and Medicaid Services (CMS) has
changed its guidance for coding Section P4-Devices and Restraints. This
new guidance will reverse the coding instructions given in August 1996.
The intent of Section P4 – Devices and Restraints in the RAI User’s
Manual is, "to record the frequency, over the past seven days, with
which the resident was restrained by any devices listed below at any time
during the day or night." The intent is followed by the definition of
"physical restraint". The manual is the primary source of
information providing direction on how to code the MDS. CMS periodically
posts Questions and Answers (Qs & As) in an effort to clarify coding
instructions. These Qs & As incorporate our understanding of
assessment practice and experience with MDS data analysis over time. We
believe that the July 2001 Qs & As regarding coding of Section P4
reflects the intent of the manual and the manual’s definition of a
physical restraint. That intent is to evaluate whether a device
constitutes a restraint as part of the assessment process, and then to
code only those devices listed in Section P4 that have the effect of
restraining the resident. CMS is instructing those completing Section P4
of the MDS to follow the intent of the Section and code only items that
meet the definition of a physical restraint. Since question #123 posted in
August 1996 could be interpreted as being in conflict with this
instruction, please disregard that question and follow the intent given in
the RAI User’s Manual and subsequent information provided in the July
2001 release of Qs & As. [Reference questions 3-80 and 3-81 in July
2001 CMS Qs & As document.]
Wisconsin included an edit in the HCFA Long Term Care Resident
Assessment Instrument User’s Manual – August 2000. The edit on page
3-158 incorporated the August 1996 HCFA guidance for coding. To promote
consistency a replacement page (3-158) (PDF,
7 KB)
for the Wisconsin 8/2000 edition of the LTC RAI User’s Manual (yellow
cover) is attached.
MDS Accuracy
Tips for success in improving and assuring MDS accuracy:
-
Promoting interdisciplinary communication;
-
Using the LTC RAI User’s Manual (there is a direct correlation
between MDS accuracy and the number of RAI manuals in the facility);
-
Knowing the federal nursing home requirements;
-
Providing training on the RAI process to all levels of staff
including certified nursing assistants; and,
-
Submitting MDS records at least weekly.
The Office of Inspector General (OIG), in conducting retrospective
medical record review (RMRR), has shown that there are significant gaps in
the quality of documentation. These RMRRs generally focus on payment items
used to calculate the resource utilization group (RUGs). Their findings
include:
-
17% of fields coded on the MDS differ from supporting information in
the medical record;
-
based on the medical record reviews, 14% more RAPs should have been
triggered and were not; and,
-
there are significant discrepancies in the accuracy of the RUGs when
comparing medical record documentation and MDS coding.
Resources
Questions related to MDS data encoding and submission (feedback reports, error messages
and data corrections) should be directed to either:
-
Cindy Symons, MDS Technical Analyst
[no longer available, contact Chris Benesh]
-
or
Chris Benesh, MDS/OASIS Automation Coordinator,
(608) 266-1718,
benesce@DHS.state.wi.us
Questions related to the RAI/MDS process and clinical
issues should be
directed to:
Questions related to pharmacy/medication issues should be directed to:
, Pharmacy Practice Consultant,
(608) 266-5388, engleda@DHS.state.wi.us
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