How are PPS MDS affected by LOA?

  1. 0
    i have an mds pps & leave of absence question that is stumping me.

    the trailblazer (mac) snf services manual page 71 says:
    the effect of loa on benefit days and the assessment schedule includes the following:
    * medicare part a benefit days are not taken.
    * do not code non-covered charges on loa days.
    * loa days do not interrupt the assessment schedule.
    the current mds 3.0 rai manual page 2-64 says:
    if a resident is out of the facility over a midnight, but for less than 24 hours, and is not admitted to an acute care facility, the medicare assessment schedule is not restarted. however, there are payment implications: the day preceding the midnight on which the resident was absent from the nursing home is not a covered part a day. this is known as the “midnight rule.” the medicare assessment schedule must then be adjusted. the day preceding the midnight is not a covered part a day and therefore, the medicare assessment clock is adjusted by skipping that day in calculating when the next medicare assessment is due. for example, if the resident goes to the emergency room at 10 p.m. wednesday, day 22 of his part a stay, and returns at 3 a.m. the next day, wednesday is not billable to part a. as a result, the day of his return to the snf, thursday, becomes day 22 of his part a stay.
    one document clearly says the assessment schedule changes and the other says the assessment schedule does not change.

    i called trailblazer about the discrepancy and they were not helpful. they directed me to the medicare claims processing manual chapter 6 - snf inpatient part a billing and snf consolidated billing and that had no information. they could not direct me to an mds expert and asked me to write to their freedom of info address.

    cms was no more helpful with their answer.

    i do not do billing so i do not know how loa days really affect the assessment schedule from the practical perspective. can someone please tell me and, if possible, cite a third reference that settles the discrepancy? if loa days actually affect the assessment schedule then i cannot see how the pps assessment calculator i am working on, or its predecessor, is useful without having the ability to adjust the days and dates based on loa days. please help me understand.

    thank you.
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  4. 4 Comments so far...

  5. 0
    My understanding was that even though it does not affect the assessment schedule, you can not bill for that day alone.
  6. 0
    That was my understanding, too, but the RAI Manual clearly states "The Medicare assessment schedule must then be adjusted" and that Thursday becomes day 22 instead of Wednesday. Does that mean the RAI Manual is blatantly wrong?
  7. 0
    The "assessment schedule" Trailblazer refers to is the assm't type (readm-14-30, etc.), which is not restarted when resident returns from LOA.

    Here's the same interpretation of "assessment schedule" from another FI, p8.

    The RAI is the sole authority for scheduling PPS assm'ts which both the provider and the contractor abide by.
  8. 0
    Talino, thank you for the clarification. The other FI's explanation is better than Trailblazer's.

    Given this information, the PPS Assessment Calculator needs more work. For the printable version, where everything is hand-filled, do I leave the rows that contain the daily dates blank? If an LOA can change the dates, and LOAs are fairly frequent, then there seems little point in inserting the dates since they will most likely change at some point. Better to let the MDS Coordinator pencil in the dates if they want them, right or wrong?

    For the automated version, where data is entered directly into the Excel spreadsheet, does it seem reasonable to have a section where LOA dates can be entered and the daily dates can be automatically updated? Do you think anyone will take the time to enter LOA dates so that the schedule will update? If not, then showing the daily dates is pointless and highlighting the Change of Therapy assessment due dates is pointless. Opinions please.

    Thank you in advance for your time. I want the PPS Assessment Calculator to be as useful as possible but I don't want to waste time on functionality that no one will use. Your input is greatly appreciated.


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