Inactivation

Talino · May 16, 2012

If the discharge was “return anticipated” the assm’t submitted was indeed incorrect.

Ironically, even though the 5-day was correct, the combined Admission cannot be inactivated separately. Hence, you will be compelled to do an entirely new assm’t (5-day/SCSA) w/ today’s ARD and all info ending on this observation date. The 5-day, being late, will only be paid the default RUG from DOA until the 14^th day. Document this oversight since your SCSA will now be more than 14 days from the actual day it was identified. Retain the original care plan dates. Retain the assessment in error/inactivated. Expect warnings when submitting the new MDS.

The 14-day and 30-day are not affected. Bill accordingly.

Your situation is one harsh example the new rule “bestows” on the industry. Unless you have a high-end full-featured software to edit every detail of an assessment or dedicated co-workers to triple check, you may want to recruit your relatives to participate in checking the accuracy of your dates and assessment types. Albeit, this would be an excellent role for the Administrator to partake!

sls73 · May 16, 2012

Thanks! Are you combining your 5D with the sig change? I read in an AANAC newsletter that CMS is billing default rates if you combine these two assessments- due to a computer glitch. I wasn't sure if it was better to split the two apart and submit separately until they fix it or not.

Curious to see what the say at the open forum on the 24th. Last I heard they had no resolution to the issue.

Talino · May 16, 2012

If it is, you wouldn't want to go through that turmoil.

However, in your scenario, you are completing a 5 day with a new ARD that is way outside the window. Combined or not, you will still get paid the default rate for the 14 days.

andy3k · May 17, 2012

Regarding the default for SCSA/5-day: CMS staff responded that this is not a glitch but simply CMS following Medicare billing guidelines and the effect of combining a SCSA with a PPS 5-day or return/readmit with an ARD of days 1-5.

A SCSA ARD must be set between day 1 and day 14 after determination the criteria is met. Therefore, staff do not have to combine it if the ARD for their 5 day or readmission PPS MDS is days 1-5. When a resident returns to the facility to begin a Medicare Part A stay, sometimes it is determined that a SCSA MDS is due. If staff does not want an AAA default RUG up to the ARD of their 5 day or readmission PPS MDS, staff need to:

1. Set the SCSA ARD for day 6, 7 or 8 and combine with the 5 day/readmission, or

2. Set the ARD for the 5 day/readmission on day 1,2,3,4 or 5 and set the SCSA ARD for day 9, 10, 11 or 12 and also check A0310B=07, or

3. Set the ARD for the 5 day/readmission on day 1,2,3,4 or 5 and set the SCSA ARD for day 13 or 14 and combine with the 14 day.

sls73 · May 17, 2012

Thanks for the information, much appreciated!

imkaren2 · May 21, 2012

I'm wondering what other MDS and CCMs are doing in the case where your medicare patients are admitted late friday after you go home and are discharged to the hospital or expire before you return on monday and you aren't able to set and ARD.

Are you taking the default days, are the floor nurses setting the ARDs for you, are the unit managers, DONs setting the ARDs?

We are being asked now to plan for this after being taken off salary, we don't work weekends so I'mm looking for a plan. thanks!

Talino · May 22, 2012

The ARD can be set and/or adjusted at any time as long as you're within the permitted ARD window. Hence, when you come in on Monday, you can set the ARD on the day or before DC or death.

In instances when the ARD window (including grace days) ends on a Sunday or a holiday and the ARD has not been set yet, there is no reason why an on-duty nurse cannot assume the responsibilty. The facility, however, should have a policy in place.

This scenario is very common with unscheduled PPS assessments. Since MDS is a teamed-based assm't, it is not a bad idea to have the therapist set the ARD, too.

andy3k · May 22, 2012

And a reminder that setting the ARD requires that it be documented on an official MDS form, paper or electronic, along with enough information to identify the resident and assessment e.g. SSN and Reason for Assessment.

imkaren2 · May 22, 2012

I thought so too but after reading the RAI in ch 2, it appears that the ARD needs to be set prior to d/c. Our company has stated that and I'm reading it that way also. Only then you are able to modify the ARD to the d/c date.

The RAI is saying that once the pt no longer is a med A pt hence is d/c you are no longer able to set the ARD.

I'd love it if someone else would read it and give me another interpretation. Thanks for anyones help!

andy3k · May 23, 2012

Clarification on Adjusting the ARD for a Scheduled Medicare MDS

Centers for Medicare and Medicaid Services (CMS) staff have clarified that when a resident on a Medicare Part A stay is discharged, the Assessment Reference Date (ARD) of a scheduled Medicare Prospective Payment System (PPS) assessment may be adjusted to the day the resident is discharged only when the ARD for the scheduled PPS assessment was set prior to the day of discharge. From page A-26 of the MDS 3.0 RAI Manual " When the resident dies or is discharged prior to the end of the look-back period for a required assessment, the ARD must be adjusted to equal the discharge date."

The ARD should be adjusted on the day of discharge or as soon thereafter as facility staff becomes aware the resident has been discharged. However, in all cases, the ARD must be adjusted no later than day 14 after discharge. As mandated on pages 2-44 and 2-45 of the MDS 3.0 RAI Manual and applicable to all required Medicare PPS MDS, " Must be completed (Item Z0500B) within 14 days after the ARD (ARD + 14 days)." Beyond 14 days after discharge, the scheduled PPS assessment becomes a missed assessment.

The following three scenarios illustrate this guidance:

Scenario One: Facility staff set an ARD for day 8 for a PPS 5 day. On day 5, the resident was discharged. On the day of discharge or 1 to 14 days after discharge, staff can adjust the ARD to day 5, as long as the PPS MDS is completed no more than 14 days after the adjusted ARD.

Scenario Two: Facility staff set an ARD for day 18 for a PPS 14 day. On day 17, the resident was discharged. Fifteen or more days after discharge, staff can NOT adjust the ARD to day 17.

Scenario Three: Facility staff had a resident admitted for a Medicare Part A stay. Facility staff never set an ARD in the facility MDS software or on an MDS item set for a PPS 5-day. On day 3, the resident was discharged. Facility staff can NOT adjust the ARD to day 3 because there is no ARD to adjust. From page 2-72 of the MDS 3.0 RAI Manual:

"If the SNF fails to set the ARD prior to the end of the last day of the ARD window, including grace days, and the resident was already discharged from Medicare Part A when this is discovered, the provider cannot complete an assessment for SNF PPS purposes and the days cannot be billed to Part A. An existing OBRA assessment (except a stand-alone discharge assessment) in the QIES ASAP system when specific circumstances are met may be used to bill for some Part A days. See chapter 6, Section 6.8 for greater detail."

Source: DADS Provider News, Alerts & Bulletins viewer linked from Texas MDS (DADS)

imkaren2 · May 23, 2012

yes, thats exactly what the RAI says, I didn't have my hands on it at the time but knew that...so my question was how are other facilities handling that? I know I am not working around the clock!