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Section GG Strategies: Documentation and Collaboration

Section GG has greatly evolved since 2016. It was first introduced as just a few functional items completed only for Medicare Part A residents, but now it requires 26 functional tasks for all long-term care residents. The accuracy of section GG not only impacts reimbursement but also plays a fundamental role in the resident-centered care plan and several Quality Measures. An effective approach is necessary to coordinate the interdisciplinary team (IDT), analyze the section GG data, determine usual performance, and support the coding of the MDS. This article reviews strategies IDTs can incorporate into their daily workflow to capture functional documentation and create a section GG summary note to support the team’s decisions for usual performance.

Document functional ability during the 3-day window

Most of the section GG functional tasks occur daily, some multiple times per day, but others may only occur once or not be attempted at all. Documentation to support what actually happened during the 3-day period is essential. However, CMS does not mandate how to document, allowing teams or organizations to develop their own process. Beckie Dow, RN, RAC-MT, CPC-A, CHC, clinical reimbursement specialist for Maine Veterans’ Homes, encourages teams to take advantage of their electronic health records (EHRs) to help collect this information. “If nurses are documenting on section GG during the 3-day period, the team may be able to develop electronic documentation templates to help guide nurses through the different functional tasks that require documentation.” This process may require nurses to interview the aides who provided direct care regarding how the resident performed, or the nurse may have assisted or observed the tasks. Facilities may also opt for nurse aides to document on the specific tasks, either on paper or electronically, during the 3-day period.

Regardless of the method used to document performance during the 3-day period, excellent communication and ongoing training is key. The 3-day period varies depending on the type of assessment and kind of discharge, requiring the nurse assessment coordinator (NAC) to ensure the team is aware of when documentation is required for each resident. Additionally, at times a discharge is unplanned and section GG data is still required. So an extra process is needed to interview the staff across all shifts and gather information about performance during that 3-day period.

Note: See AAPACN’S Section GG 3-Day Assessment Periods and Algorithm tool for additional clarification on different look-back periods.

Collaborate with IDT meetings to write the GG Summary Note

After collecting the performance documentation, the team must establish and document the resident’s usual performance. The process begins with an IDT meeting to review the resident’s performance during the 3-day period. The team may include nurses, nurse aides, therapists, and other relevant staff who observed or provided care to the resident. Because the determination of usual performance can occur outside of the 3-day period, this meeting can be integrated into the facility’s workflow. The team may review during a daily stand-up meeting or include it as part of the Medicare or utilization meetings.

Overall, the goal of the meeting is to identify the resident’s usual performance in each of the section GG tasks and write a summary note that supports the MDS coding of section GG. Using a template, either electronic or paper, to complete the summary note helps increase the effectiveness of this process. Dow suggests the GG summary notes should include at least the following information:

  • Identify the date the team met to review documentation.
  • Recognize the specific 3-day performance period documentation reviewed during the meeting.
  • As a team, determine usual performance for each GG task.
    • If documentation during the window consistently supports the usual performance, no additional documentation is needed to validate the MDS coding.
    • If the performance varied throughout the course of the 3-day period, document the additional rationale used to determine usual performance.
    • For 5-day assessment only, document if the resident benefited from treatment intervention for any tasks and when the change occurred.
  • Address any functional goals established during the meeting.

Strategies for effective documentation

One strategy recognizes the purpose and use of the documentation collected, helping increase the value of the data to team members. “GG data is used for reimbursement, for MDS 3.0 Quality Measures, skilled nursing facility (SNF) Quality Reporting Program (QRP) Measures, identifying functional goals, and care planning,” Dow explains. To support these different uses, detailed observations and accurate documentation regarding the resident’s performance in various activities, level of assistance required, and any safety concerns is vital.

A second strategy focuses on the 3-day period, a very narrow window. Dow cautions that “staff may be tempted to use data from beyond the 3-day period” but warns that “even though this may show a more comprehensive picture of how the resident performs, the team must keep the scope with the 3-day period.” She further explains that additional information and performance data may be beneficial for care planning and goal setting, but data beyond the 3-day period may not be considered for MDS coding.

Another strategy is ongoing education and validation of the data collection process. There are many different section GG tasks and a complex level of assistance scale. To verify accuracy, observe the care provided by staff and then review how that care was documented. This strategy allows for real-time and real-life application and education. Dow also stresses the need for ongoing oversight over the nurse aide documentation: “Nurses need to identify if there are any gaps that need to be clarified or any misunderstanding on the different levels of care.”

Lastly, strong communication between the NAC, nurses, nurse managers, and nurse aides is paramount to ensure accuracy. Dow states, “The NAC needs to get out there and talk to staff and residents. Section GG is not just about counting the numbers; there is no Rule of 3. They need to really understand how the resident is performing during the 3-day period.” This strategy also helps the NAC identify any fluctuations between different shifts or staff, the reasons a resident may not be performing an activity, or what treatment interventions have proven to benefit a new resident.

Conclusion

Accurately coding section GG on the MDS requires a coordinated effort from the entire IDT. By integrating team meetings into the workflow, establishing a process to collect functional performance during the 3-day period, using effective templates, and nurturing strong communication, facilities can be assured of accurate assessments and resident-centered care plans.

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