Since the implementation of the RAI User’s Manual version 1.18.11 on Oct. 1, 2023, several long-term care nursing facilities have experienced electronic health record (EHR) software issues as well as complications with the MDS 3.0 Data Specifications provided by the Centers for Medicare & Medicaid Services (CMS), impacting many MDS assessments nationwide. Facilities have been unable to submit MDS assessments or have received fatal errors preventing assessments from submission. These software issues have created delays, causing a record of late MDS submission for many assessments for facilities.
CMS responded to concerns about these software issues on the Oct. 12 Skilled Nursing Facility/Long Term Care Open Door Forum by informing providers to contact their vendor regarding any software issues and to contact their Medicare Administrative Contractor (MAC) with any questions related to billing the appropriate HIPPS code.
In addition to those solutions, this blog will provide tips for how facilities can address these issues within the facility through quality assurance and correction. By taking these steps, facilities can build a case showing their action plan to present to surveyors if needed during survey. This blog will also address different ways facilities can be proactive to double-check that their MDS submission process is completed accurately and that they are doing their due diligence as a Medicare and/or Medicaid nursing home provider to stay informed of changes.
Document all issues thoroughly
“Facilities should keep a log of the issues that they have had and include it in their Quality Assessment and Assurance (QAA) program,” advises Jennifer LaBay, RN, RAC-MT, RAC-MTA, QCP, CRC, curriculum development specialist for the American Association of Post-Acute Care Nursing (AAPACN). “They should make sure to document all issues so that they know which assessments were impacted.” LaBay recommends facilities log why there was a late completion and the root cause related to the software issue. She also advises staff to log any correspondences with the EHR vendor or CMS and include any updates CMS released related to correction.
“It’s also important to note in the documentation for QAA that although the MDSs weren’t submitted due to technical issues that prevented iQIES acceptance, care plans were not impacted, and this issue did not impact resident care,” adds Brenda Sowash, RN, RAC-CT, director of clinical assessments, standards, and practices for Trinity Health Senior Communities in Livonia, MI. Sowash also mentions that companies with multiple communities can consolidate their tracking by creating one master log available for all their communities to use in survey.
Since the August 2023 release of the final MDS 3.0 RAI User’s Manual v1.18.11, there have been three Errata documents applied to the MDS Data Specifications V3.01.1, as well as two updates to the PDPM Grouper JAR Package. For full details on the updates, visit CMS’s MDS 3.0 Technical Information webpage.
“By having these issues documented, when surveyors come into the facility and if they question why there was a delay with these submissions, the facility can respond to their lateness with evidence that the delay was related to software and data specification issues, not facility performance,” explains LaBay. “It’s best to show surveyors that the facility was aware of the issue, kept a log of the assessments they were unable to submit or had issues with, that they have everything written down, and a plan for correction.”
“Facilities should also submit assessments when they are able to,” adds Jessie McGill, RN, BSN, RAC-MT, RAC-MTA, curriculum development specialist for AAPACN. “Even if the assessment is incorrect due to software issues, it is better to submit an incorrect assessment that can be modified later than to be out of compliance with completion and submission of that assessment, as well as care plan completion.”
Follow the process for correction
During the Oct. 12, 2023, SNF/LTC Open Door Forum, the following question and answer was provided regarding modifying assessments after the November update to the MDS 3.0 Data Specifications:
An attendee asked, “Does that mean when we [code an MDS item] now and we, a lot of people, are just having to dash it to get it to be able to close the MDS, will we be able to modify an MDS after November’s files are updated? And then will it then be able to fix this issue for these October MDSs about respiratory therapy and psychological therapy that can affect state case mixes that are using the PDPM components?
A CMS official answered, “So, after the errata fix goes into effect on November 1, you will be able to go back to assessments that did not have those items active. You will be able to go back and do corrections if you choose to. CMS is not requiring you to do that. However, if you need to do that, you can go back and correct it. Also, with the retroactive onset, what will happen is if a provider goes back to correct an assessment completed between October 1 and 30, they will have to complete those items to close that MDS.
During the CMS SNF/LTC ODF held Dec. 7, 2023, an attendee asked what the course of action would be related to the MDS 3.0 Data Specification Errata that was uploaded Dec. 12, 2023, with a retroactive effective date of Oct. 1, 2023. A CMS official stated that as long as the update did not impact the HIPPS code, nothing would need to be done. If the HIPPS code was impacted, a modification should be completed for a record that has already been submitted and accepted into iQIES.
It is important for staff to follow the RAI User’s Manual coding instructions when completing the modification for assessments they choose to correct, says LaBay. “Facilities cannot backdate, even if it’s a software error. When making the needed corrections, they should date the assessment with the current date it was completed. And tracking these modifications should be part of the facility’s QAA process.”
Implement multiple MDS checks and balances
Check CMS resources for updates and be proactive with software issues
Facilities staff can be proactive by checking CMS’s MDS 3.0 Technical Information webpage in addition to the MDS 3.0 RAI User’s Manual webpage, says LaBay. “It’s the facility’s responsibility to be informed and to act when there are issues. Facilities can’t just rely on the software vendors to find mistakes. They need to know what should be happening in the software to accurately reflect the assessment. If something isn’t working properly, facilities should inform the software vendors of what they need and provide examples and proof of the issue to their vendor so that it can be fixed.”
Keep a separate schedule
“It’s also very important to keep a separate schedule for MDS completion apart from what is in the software,” suggests LaBay. “Facilities can utilize this separate schedule as a double-check to make sure they didn’t miss anything and that things aren’t out of order when they are submitting. They can check to make sure they have completed everything that is on their list. They can also go back and make sure their schedules are accurate.”