On Aug. 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the final MDS 3.0 RAI User’s Manual version 1.19.1 that will be effective Oct. 1, 2024. Although nurse assessment coordinators in skilled nursing facilities have been preparing for these changes, when asked how prepared they are for the updates, AAPACN members who responded to the September 2024 Leader for the NAC Member Feedback Survey indicated that only 14% feel they are very prepared, with the majority of respondents (86%) saying they are only somewhat prepared (48%), neither prepared or unprepared (19%), somewhat unprepared (5%), or very unprepared (14%).
To assist members in their preparation, this AAPACN blog will highlight the top 3 RAI User’s Manual updates and some key points to keep in mind with these changes, as well as provide additional resources to help NACs be ready for Oct. 1.
1. Section I, Active Diagnoses: New instructions for coding sepsis as septicemia. The updated RAI User’s Manual states on page I-13:
For sepsis to be considered septicemia, there needs to be inflammation due to sepsis and evidence of a microbial process. If the medical record reflects inflammation due to sepsis and evidence of a microbial process, code I2100, Septicemia. If the medical record does not reflect inflammation due to sepsis and evidence of a microbial process, enter the sepsis diagnosis and ICD code in item I8000, Additional Active Diagnoses.
When discussing this change in a recent LTC NAC Chat podcast, AAPACN curriculum development specialist, Jessie McGill, RN, BSN, RAC-MT, RAC-MTA, states, “The inflammation, when we are talking about sepsis, is often a multi-organ system inflammation. So, this may present with something such as a fever, a rash, or joint aches. There are a lot of different ways that the inflammation can be present in the medical record, and it’s important that when the NAC is coding sepsis under septicemia that they are really looking for the evidence of inflammation and the different types of inflammation and how it may present in this resident with their infection.”
Note: AAPACN members can access the new AAPACN tool, Sepsis: Nurse Documentation Training Aide, to provide guidance to nurses on assessment and documentation needs when a resident is diagnosed with sepsis.
2. Section GG, Functional Abilities: Removal of discharge goals.
In the change tables released with the updates for the RAI User’s Manual v1.19.1 (found on the CMS MDS 3.0 RAI Manual webpage under the Downloads section), CMS indicates the removal of discharge goals from section GG coding requirements.
“What the NACs will see this October is that when you are completing your admission or your 5-day, you are only going to be coding the admission performance,” says McGill about this update. “You will no longer also be coding the goal in column 2—column 2 is completely gone. All the coding instructions about goals were also removed. Some of the skip patterns and examples were updated as well.”
McGill emphasizes that although the requirement to include a goal was removed from the MDS, NACs should still continue this practice to set and work toward functional goals and discharge goals for each resident. AAPACN members can read more on this change in an upcoming Leader for the NAC newsletter article, “GG Goals: Not Really Gone.”
3. Section O, Resident’s COVID-19 vaccination is up to date.
CMS added item O0350, Resident’s COVID-19 vaccination is up to date, to track this vaccine status for each resident and to update MDS coding to be in line with the new SNF Value-Based Purchasing measure, COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine) measure, which will begin public reporting in FY 2026. The rationale, steps for assessment, coding instructions, definition, and coding tip for this new item are on pages O-19 – O-20 of the updated RAI User’s Manual.
This change impacts “all of your OBRA assessments and your Medicare assessments,” says McGill. “We’re coding this on every assessment, just like we do for the flu and pneumococcal vaccines.”
McGill notes that it’s important to be aware of what the Centers for Disease Control and Prevention (CDC) defines “up to date” as in their guidance. NACs will need to stay abreast of any changes to this term as they code this new item for each resident.
Review the CDC’s Stay Up to Date with COVID-19 Vaccines webpage for details on the latest definition for “up to date.”
For more information on the updates to the RAI User’s Manual for this Oct. 1, listen to the LTC NAC Chat podcast, “Top Five Changes in the RAI User’s Manual for October 2024” and the AAPACN on-demand webinar, Small Updates, Big Impact: October 2024 RAI Manual Changes, and read the article, “Draft RAI User’s Manual v1.19.1 Study Guide: Key Changes to Review.”