Section GG is one of the most challenging sections of the Minimum Data Set (MDS). The instructions alone span 36 pages in the Long-Term Care Facility Resident Assessment Instrument 3.0 User’s Manual (RAI User’s Manual). Complex task definitions, a nuanced performance scale, and a narrow 3-day assessment period create numerous opportunities for coding errors and misconceptions.
The stakes are high. Section GG is more than a functional assessment used to inform the care plan. Its data affects Medicare reimbursement under the Skilled Nursing Facility Prospective Payment System (SNF PPS), Medicaid reimbursement in many states, multiple quality measures (QMs), and the Skilled Nursing Facility Quality Reporting Program (SNF QRP) compliance. In some situations, failure to assess even one section GG task can reduce a facility’s Annual Payment Update (APU).
However, not all section GG assessments carry the same regulatory significance. Some assessments contribute to Medicare payment and SNF QRP reporting requirements. Others primarily support resident assessment, care planning, and quality monitoring. Understanding this distinction is critical for nurse assessment coordinators (NACs), who must balance compliance, reimbursement, and accurate resident assessment. This article explains how the use of section GG differs on OBRA and PPS assessments. It also clarifies when GG data affects payment, SNF QRP compliance, and quality reporting.
Section GG: OBRA versus PPS Assessments
Because section GG functional tasks are coded on both OBRA and Medicare PPS assessments, assuming the data serves the same purpose every time makes sense. But it can lead to confusion about payment, quality reporting, and compliance requirements. To understand how section GG is used, NACs must first understand how OBRA and PPS assessments differ.
OBRA Assessments
OBRA assessments, required under federal nursing home regulations, support comprehensive resident assessment and care planning. They consist of the Admission assessment, Quarterly assessment, Annual assessment, Significant Change in Status Assessment (SCSA), Significant Correction assessment, and OBRA Discharge assessments. Together, these assessments offer an ongoing picture of the resident’s functional status, clinical condition, and care needs throughout the stay. They ensure each resident is evaluated accurately, along with the development of a comprehensive individualized care plan. The assessments are also used for MDS 3.0 QM calculations but not for SNF QRP.
Medicare PPS Assessments
Medicare PPS assessments serve a different purpose. Tied to Medicare Part A reimbursement, they include the 5-Day PPS assessment, PPS Discharge assessment, and the Interim Payment Assessment (IPA). Their primary purpose is collecting information to determine Medicare payment. The 5-Day assessment is also used in the MDS 3.0 QM program; the PPS Discharge assessment and IPA are not. Only the 5-Day and PPS Discharge assessments are used in the SNF QRP measure calculations.
Key Differences
Because section GG appears on both OBRA and PPS assessments, facilities often assume the coding carries the same financial and regulatory consequences. Understanding the different ways the data is used is key for targeted audits and understanding compliance risks. The following chart delineates these differences.
| Assessment Type | Assessment Name(s) | Purpose of Section GG | Used for MDS 3.0 QMs? | Used for Medicare Payment? | Used for SNF QRP? | Dashes Count Against APU Threshold? |
| OBRA Assessments | Admission, Quarterly, Annual, SCSA, Significant Correction, OBRA Discharge | Resident assessment, care planning, monitoring functional status throughout the stay | Yes | No | No | No |
| PPS Assessment | 5-Day | Establishes functional status for Medicare reimbursement and quality reporting | Yes | Yes | Yes | Yes |
| PPS Assessment | PPS Discharge | Establishes functional status for quality reporting | No | No | Yes | Yes |
| PPS Assessment | IPA | Establishes functional status for Medicare reimbursement | No | Yes | No | No |
Note: Medicaid reimbursement varies by state program methodologies. Check with your state program to determine how section GG is used and which assessments are needed.
Key Takeaway
Understanding how section GG is used on different assessments helps NACs complete more targeted audits. They can direct resources toward assessments that carry the greatest reimbursement and compliance risk while maintaining accuracy across all assessment types.
Section GG: Affecting Payment
Section GG plays a significant role in reimbursement. Under the Patient-Driven Payment Model (PDPM), resident function is one factor used to classify residents into case-mix groups for the Nursing and Physical Therapy (PT)/Occupational Therapy (OT) components. Additionally, many state Medicaid programs also use section GG as part of their payment methodology.
For Medicare reimbursement, the functional score is derived from a subset of the 29 section GG self-care and mobility items completed on the Medicare 5-Day PPS assessment. Of these items, 10 are used for the PT/OT component and 7 for the Nursing component. Because section GG can influence payment classification, coding accuracy is critical. However, the NAC does not need to audit the entirety of section GG for payment accuracy, since only 10 of the items are used.
Of note, not all Medicare assessments are used for payment. As shown in the previous chart, only the Medicare PPS 5-Day and the IPA are used for Medicare reimbursement. The Medicare PPS Discharge is only used for SNF QRP reporting. When auditing or providing supporting documentation for a medical review, only the 10 GG items used for payment need to be addressed, not all 29 tasks.
Medicaid payment varies by state. Some of them only use section GG data on OBRA assessments. Others also include Medicare assessments in the methodology. States that use a PDPM-based methodology also only use the subset of GG items. The following chart details the 10 section GG items used in PDPM methodology.
| GG Item | Scoring | Used in PT/OT Component | Used in Nursing Component |
| GG0130A. Eating | Individual score | X | X |
| GG0130B. Oral hygiene | Individual score | X | |
| GG0130C. Toileting hygiene | Individual score | X | X |
| GG0170B. Sit to lying | Average score | X | X |
| GG0170C. Lying to sitting | |||
| GG0170D. Sit to stand | Average score | X | X |
| GG0170E. Chair/bed-to-chair transfer | |||
| GG0170F. Toilet transfer | |||
| GG0170J. Walk 50 feet with two turns | Average score | X | |
| GG0170K. Walk 150 feet |
Key Takeaway
Although section GG plays an important role in both Medicare and Medicaid reimbursement, not every GG item and not every assessment affects payment. Understanding which assessments and which GG items are used in payment calculations allows NACs to conduct more focused audits, target documentation review efforts, and better identify areas of true reimbursement risk rather than treating all 29 GG tasks as equally significant.
Section GG: SNF QRP Compliance
Perhaps no aspect of section GG creates more confusion than its relationship to SNF QRP compliance. Many NACs believe a single dash in section GG, as well as other MDS items, can jeopardize the facility’s Medicare APU, leading some SNFs to scrutinize every dash on every assessment. The concern is understandable, but not all assessments are treated equally under SNF QRP.
The SNF QRP was established by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act to standardize quality reporting across post-acute care (PAC) settings. Under the program, SNFs must submit required assessment data elements for residents covered by Medicare Part A. Those that fail to meet the reporting requirements are penalized with a 2% reduction to their Medicare APU, affecting Medicare payment for an entire fiscal year.
Because section GG is included on both OBRA and PPS assessments, facility staff may assume that any dashed GG item on any assessment could place their APU at risk. But in reality, SNF QRP compliance is based only on specific assessments, the Medicare 5-Day PPS assessment and the Medicare PPS discharge assessment. However, unlike PDPM, the SNF QRP program uses 27 GG items, only excluding GG0130I (Personal hygiene) and GG0170FF (Tub/shower transfer). The AAPACN tool, MDS Items Impacting Reimbursement PDPM and SNF QRP, can help delineate the items used for each program.
Although the IPA is a Medicare assessment, it is not used in SNF QRP calculations or compliance thresholds. Likewise, stand-alone OBRA assessments—Admission, Quarterly, Annual, Significant Change, Significant Correction, and OBRA Discharge assessments—are excluded from SNF QRP measure calculations and compliance thresholds. This distinction is particularly relevant when considering dashes that may impact the SNF QRP reporting threshold. A common misconception is that a dash coded on a stand-alone OBRA assessment could cause a facility to miss the APU threshold. Of course staff should always follow the coding instructions outlined in the RAI User’s Manual, but the compliance risk associated with missing data exists only on the assessments used for SNF QRP reporting.
Key Takeaway
Understanding which assessments are included in SNF QRP calculations allows NACs to better prioritize audits, target compliance efforts, and focus resources on areas of genuine regulatory risk.
Section GG: Quality Reporting
Although section GG is often associated with payment and SNF QRP compliance, its role in quality measurement is much broader. One common misconception is that SNF QRP and MDS 3.0 QMs are the same. Although both programs use MDS data and some overlap occurs in the assessments used, they are separate reporting systems with different purposes, measure specifications, and assessment selection criteria.
The MDS 3.0 QMs are used throughout the nursing facility population to evaluate resident outcomes and facility performance. These measures support programs such as Care Compare and provide facilities with information about trends in quality of care and resident outcomes. They rely on data collected from OBRA assessments and the PPS 5-Day assessment that capture residents across their entire stay, regardless of payer source.
SNF QRP, in contrast, focuses specifically on Medicare Part A residents receiving skilled services. The program evaluates outcomes during a Medicare stay and facilitates comparisons across PAC settings. Several SNF QRP measures rely heavily on MDS data but only use data from the Medicare PPS 5-Day and the PPS Discharge assessment.
Key Takeaway
Understanding which assessments and GG columns used by each reporting program allows NACs to conduct more targeted audits and better evaluate actual quality reporting risk.
Conclusion
Section GG may be a single section of the MDS, but it serves multiple purposes across reimbursement, quality reporting, compliance, and resident assessment. Accurate coding of all 29 items is essential to complete an assessment and develop a resident-centered care plan. But it is also useful to understand how the Centers for Medicare & Medicaid Services (CMS) uses the submitted data.
Understanding the different ways section GG data is used allows NACs to conduct more targeted audits, prioritize compliance risks appropriately, support reimbursement accuracy, and strengthen the integrity of the assessment process. When facilities move beyond the misconception that all section GG coding carries the same consequences, they are better positioned to balance regulatory compliance, financial stewardship, and resident-centered care.
This AAPACN resource is copyright protected. AAPACN individual members may download or print one copy for use within their facility only. AAPACN facility organizational members have unlimited use only within facilities included in their organizational membership. Violation of AAPACN copyright may result in membership termination and loss of all AAPACN certification credentials. Learn more.