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Slide 1 This presentation is based on the rules and
practices in place as of December 2013, and will cover automated and clinical correction's
as related to MDS 3.0.
Slide 2 Why accuracy? On this slide I have listed
some uses of the MDS data, so accuracy of the MDS is key, and impacts many areas.
Slide 3 OBRA 87...states that assessments are to be
accurate. Also the code of federal regulations states
the assessments must accurately reflect the residents status.
4 So after reviewing various reports or MDS
records you determine an error exists on a record and you know the MDS must accurately
reflect the resident's status, so what do you do?
5 Our first route is to determine if the record
was received by the national database ASAP system or not.
We will begin with a record that has not been received.
6 During the first 7 days after completing a
resident's MDS assessment or tracking information, facilities have up to 7 days to encode and
edit the electronic MDS record that has been completed. Changes may be made to the MDS
record for any item during this time, provided the responses refer to the same observation
period.
7 During this edit phase you are allowed to
make revisions to the paper copy by drawing a line through the previous response, enter
the correct response, initial and date the corrected entry, similar to how an entry in
a medical record is corrected.
8 It is very important that the MDS data is
entered accurately into the software and that these responses match the paper form. Any
discrepancies noted must be completed during the 7 day encoding period.
9 Always remember that the edit process is completed
based on the software program and that the record has not been received by ASAP and would
still be reflected as a 1 at A0050, add new record.
10 For new users I suggest you contact the vendor
on what steps are required to edit the record that has not been received by ASAP. After
completion of the edit phase you will transmit the record within the regulatory timeframes.
11 This next section addresses "what to do" if
you find an error on an MDS record that has been submitted and accepted into the federal
database (ASAP).
12 So now you have discovered an error exists
on a record that has been accepted into ASAP. You know you need to modify that record, in
other words make a correction to the record.
13 A modification to a record can be used to
correct most items. Some examples include target date, for an
entry, discharge or death record.
14 Additional examples include assessment reference
date, reason for assessment and clinical items detected within section B through V.
15 Note: The ARD (Item A2300) can be changed
when the ARD on the assessment represents a data entry/typographical error. However,
the ARD cannot be altered if it results in a change in the look back period and alters
the actual assessment timeframe.
16 The Type of assessment items (Item A0310)
can only be modified when the Item Set Code (ISC) of that assessment does not change.
In other words, if the Item Subset would change, the modification cannot be done.
You can also reference tables on pages 2-77 and 2-78 for ISC's.
17 An Admission assessment (item set code = NC,
nursing home comprehensive) was completed and accepted into the ASAP system. The provider
intended to code the assessment as an Admission and a 5-day PPS assessment (ISC = NC). The
modification process could be used in this case as the ISC would not change.
Key word here is ISC code is not changing. So modification would be allowed
18 Example, a stand-alone Discharge assessment
(ISC = ND) was completed and accepted into the ASAP system. The provider later (that
is, after the day of discharge) determined that the assessment should have been a 30-day
PPS assessment combined with a Discharge assessment (ISC = NP).
19 Solution, this modification would not be allowed
as the ISC for the Discharge assessment combined with the 30-day PPS is different than the
stand-alone Discharge ISC. This is an example of a missing 30-day assessment. Key words
= Item Set Code (ISC) changes.
20 You may want to contact your software vendor
on your first modification of your correction to learn how to retrieve and modify the erroneous
record, or you may create additional work for yourself. You want to determine how the
vendor handles completion of section X for the Prior record information which we will
cover shortly.
21 Let's take a closer look at the completion
of section X.
22 Since we are currently reviewing the modification
of a record you will code A0050 as a 2. Remember we are completing a modification
of a MDS record that was received by ASAP.
23 Complete X0150 as appropriate, nursing home
or swing bed. X0200 is the resident's name as it appears
on the record to be modified or the way the original record was received by ASAP.
24 X0300 and 400, gender and birth date, is prior
record information from when the original record was received which is used by ASAP
to identify and locate the record to be modified.
25 Again, this is prior record information used
to identify the received erroneous record in ASAP.
Note if multi coded reason for assessment all types of the original reason for assessment
have to be included with sections X0600 A,B,C,D & F.
26 X0700 is also an identifier of the record
to be modified, again based on how the record was originally received.
X0800 represents the number of times the record has been modified. For example, 01 equals
the 1st time the record is modified, 02 would be the second time that the original record
has been modified and so on.
27 X0900 is the reason you are modifying the
record. Note to check all that apply.
28 X0900 defined
(a) Transcription Error (For example, weight is 119 and entered as
191) (copied wrong from other source) (b) Data Entry Error
(e.g. individual therapy minutes entered as 3000 minutes when minutes should have been
300)
29 (c) Software Product Error
(e.g. software stored weight as 20 rather than 200)
(d) Item Coding Error (e.g. coding a 4 in ADL's self performance
when it should have been a 2) (z) Other error
If other please specify
30 X01100 represents the RN attestation which
includes name, title signature and date. This person must be an RN.
31 Until you are comfortable doing modifications,
your software vendor should be consulted, on how to retrieve the accepted record in
order to modify.
32 After modification, the corrected record replaces
the erroneous record and becomes the new current version.
The erroneous record is placed in the history file for the facility.
33 You want to save the old MDS record, the new
MDS record and the completed and signed section X.
Document in your chart any reasons related to the error and modification.
34 The Federal regulatory requirement at 42 CFR
483.20(d) requires nursing homes to maintain all resident assessments completed within
the previous 15 months in the resident's active clinical record. This requirement applies
to all MDS assessment types regardless of the form of storage (i.e., electronic or hard
copy).
35 Nursing homes also have the option for a resident's
clinical record to be maintained electronically rather than hard copy.
In cases where the MDS is maintained electronically without the use of electronic signatures,
nursing homes must maintain, at a minimum,
36 Hard copies of signed and dated CAA(s) completion
(Items V0200B-C), correction completion (Items X1100A-E), and assessment completion (Items
Z0400-Z0500) data that is resident-identifiable in the resident's active clinical record.
Nursing homes must also ensure that clinical records, regardless of form of storage, are
easily and readily accessible to staff (including consultants),
37 State agencies (including surveyors), CMS,
and others who are authorized by law and need to review the information in order to provide
care to the resident.
38 This includes all MDS (including Quarterly)
assessments and CAA(s) summary data completed during the previous 15-month period.
39 Additional detail related to storage and location
of MDS data can be located in the RAI manual pages 2-5 to 2-7.
40 It is important to save the modification documentation
which verifies that the erroneous record was corrected in the event an auditor would require
verification that the error was corrected. Document in your chart the date the error
was discovered. You also want to ensure the correction was completed and signed at X1100E
within 14 days of error discovery.
41 Note that the modification of one record does
not correct other records with the same problem, in other words you may have to do modifications
to other records with the same problem.
42 An Inactivation should be used when a record
has been accepted into the QIES ASAP system but the corresponding event did not occur.
For example, a Discharge assessment was submitted for a resident, but there was no actual discharge.
An Inactivation (Item A0050 = 3) must be completed when any of the following items are inaccurate:
43 Type of Provider (Item A0200)
Type of Assessment (A0310) when the ISC would change had the MDS been modified
Entry Date (Item A1600) on an Entry tracking record (Item A0310F = 1) when the look-back
period and/or clinical assessment would change had the MDS been modified.
44 Discharge Date (Item A2000) on a Discharge/Death
in Facility record (Item A0310F = 10, 11, 12) when the look-back period and/or clinical
assessment would change had the MDS been modified. Assessment Reference Date (Item A2300) on
an OBRA or PPS assessment when the look-back period and/or clinical assessment would change
had the MDS been modified.
45 Inactivations should be rare. In the event
a new record has to be created as a result of the inactivation, the new ARD must be established
based on the date the error was discovered or later, but not earlier.
46 In the event a new record is created. New
signatures will be required based on the new assessment reference date.
47 For inactivations, A0050 will be coded as
a 3 to reflect inactivation.
48 Sections X0200 through X0800 is completed
just like the modification of a record, which is used to locate the existing record in ASAP
which you want to inactivate.
49 At X1050 you will check all that apply as
related to why you are inactivating the record.
50 I recommend that you contact your vendor when
completing your first inactivation to determine how you retrieve the existing record in order
to complete the inactivation. This process should be handled similar to modifications.
51 Be aware that after the inactivation is submitted
that there is no remaining active version of that record in the Federal database. The
inactivated record is moved and stored in the facilities history file by CMS.
52 Note that the completion of the record is
required within 14 days from error detection and X1100E must be signed within 14 days from
detection of the error.
53 A somewhat new warning message of 1061 on
the validation report may appear and indicate improper coding based on a change with the
Reason for Assessment or Assessment Reference Date.
54 Another new 1062 warning may appear on the
validation report that may reflect a change in the target date and/or RFA in combination
with a change in the clinical item listed and Medicare RUG may indicate improper coding.
Other clinical items may also have changed.
55 The fatal error message 3839 may appear on
the validation report in which you try to modify a record that does not use the same
ISC of a record you are trying to modify.
56 Some records may require the complete removal
of a transmitted and received record residing in ASAP. In order to accomplish this, a manual
correction request form is required. Some examples would be that the record was accepted
with an incorrect facility ID or a test record sent as production. Note that test records
are no longer accepted by ASAP.
57 Another example for removal of a record would
be a Medicare only assessment that is not a Medicare part A stay but rather HMO.
58 Be aware that nursing homes are required to
submit Omnibus Budget Reconciliation Act required (OBRA) MDS records for all residents in a
Medicare or Medicaid-certified bed regardless of the pay source.
59 Assessments that are completed for purposes
other than OBRA and SNF PPS reasons are not to be submitted, e.g., private insurance,
including but not limited to Medicare Advantage Plans.
60 The manual deletion request form must be obtained
from your Oklahoma QIES department. This form must be completed and returned via certified
mail to the Oklahoma QIES department. Our department reviews for accuracy and then forwards
to the National QIES help desk via certified mail.
61 Please work the following scenarios and then
go to the answer page to see how you did.
62 A facility submits a record and later modifies
it. Then the facility discovers that the earlier record was correct after all. The later (active)
version of the record is in error. What do you do?
63 A facility completed a Discharge Assessment
on a resident. Later, they discovered they submitted the discharge on the wrong resident.
What do you do?
64 A facility discovers a valid MDS assessment
contains many miscoded items for all the interview sections and the ADL's on the admission assessment
that was transmitted and accepted in the database. What do you do?
65 When entering the assessment into the facility's
software, the ARD, intended to be 10/12/2013, was inadvertently entered as 10/02/2013.
The interdisciplinary team (IDT) completed the assessment based on the ARD of 10/12/2013
(that is, the seven day look back was 10/06/2012 through 10/12/2013.
What do you do?
66 An Admission assessment (ISC = NC) was completed
and accepted into the ASAP system. The provider intended to code the assessment as an Admission
and a 5-day PPS assessment (ISC = NC). What do you do?
67 Modification vs. Significant Correction vs.
Significant Change in Status
68 Some areas we will review are:
When do we do a Modification? When do we do a Significant Correction?
When do we do a Significant Change in Status Assessment?
So before we begin, let's review a few definitions and concepts that relate to significant errors
and corrections.
69 As discussed in the automated correction segment,
a modification is required when a valid MDS record has been accepted by the CMS MDS database,
but the information in the record contains errors. The modification will correct the
record in the CMS database. A modification is not completed when a record has been rejected.
70 A "significant error" is an error in an assessment
where: The resident's overall clinical status is
not accurately represented (i.e., miscoded) on the erroneous assessment; and
The error has not been corrected via submission of a more recent assessment.
A significant error differs from a significant change because it reflects incorrect coding
of the MDS and NOT an actual significant change in the resident's health status.
71 A significant error is an error that inaccurately
reflects the resident's clinical status and/or results in an inappropriate plan of care are
considered significant errors.
72 All other errors related to the coding of
MDS items are considered minor errors.
73 So let's review some rules
74 If an assessment was performed for Medicare
purposes only or for a discharge, no significant change in status or significant correction
to a prior assessment is required. The provider would then determine if the Medicare assessment
should be modified or inactivated.
75 The Significant correction to prior comprehensive
assessment is a comprehensive assessment for an existing resident that must be completed
when the IDT determines that a resident's prior comprehensive assessment contains a
significant error.
76 A SCPA is appropriate when:
the erroneous comprehensive assessment has been completed and transmitted into the MDS
system; and there is not a more current assessment in progress or completed that includes a correction
to the item(s) in error.
77 When discovered Nursing homes should document
the initial identification of a significant error in an assessment in the progress notes.
The ARD must be within 14 days after the determination that a significant error in the prior comprehensive
assessment occurred which is determination date + 14 calendar days.
78 The Significant Correction to Prior Quarterly
is an OBRA non-comprehensive assessment that must be completed when the IDT determines
that a resident's prior Quarterly assessment contains a significant error.
79 A Significant Correction to Prior Quarterly
is appropriate when the erroneous Quarterly assessment has been completed and has been
transmitted into the MDS ASAP system, and there is not a more current assessment in
progress or completed that includes a correction to the item(s) in error.
80 Nursing homes should document the initial
identification of a significant error in an assessment in the progress notes.
The ARD must be within 14 days after the determination that a significant error in the prior Quarterly
assessment has occurred (determination date + 14 calendar days) and no later than 14 days
after determining that the significant error occurred. (RAI, 2-32)
81 Remember, when doing significant corrections,
you will be doing the ARD in today's timeframe. The OBRA clock will reset based on significant
corrections. Remember to always Modify the erroneous assessment
along with completing the significant correction when applicable.
82 Remember SCPA and SCQA is Not required if
another assessment has been completed that addressed the significant error for quarterly
or comprehensive assessments (Modification only Required).
SCPA and SCQA are not required for errors made for a PPS only assessment.
83 When performing significant corrections to
OBRA assessments you will be required to complete A2200 which asks for the prior Assessment
reference date of the last assessment in error.
84 A significant change differs from a significant
error because it reflects an actual significant change in the resident's health status and
NOT incorrect coding of the MDS. If a significant change in status is identified
in the process of completing any assessment except Admission and SCSAs, code and complete
the assessment as a comprehensive SCSA instead.
85 Remember to always modify the erroneous record
when accepted in ASAP. If a significant error is identified, then
a new Assessment Reference Date for the Significant Correction (current time) is required.
Since error, no other assessment has addressed the significant error, then the Significant
Correction is required.
86 Clinical Q&A's
Refer to the separate Q&A handout for solutions.
87 The facility discovers that a valid OBRA assessment
contains inaccurate information. The assessment has been transmitted and accepted
into the ASAP database. No other assessment has been performed since
the error occurred.
88 The Interdisciplinary team reviewed the resident's
record and determined the prior assessment errors were Significant errors.
On further review, the team found significant changes also occurred with the resident's
condition since the last assessment. The assessment has been transmitted and accepted
into the ASAP database. What do I do?
89 The facility discovers that a valid OBRA assessment
contains inaccurate information. The assessment has been transmitted and accepted
into the ASAP database. There has been no other assessment performed
since this one. The interdisciplinary team reviewed the resident's
record and determined the assessment errors were not Significant errors.
What do I do?
90 Three errors are found in Ms. T's Assessment;
A0310A = 99; A0310B = 1. Incorrect SS#
Incorrect Gender M0300C = 0 (# of stage 3 pressure ulcers)
when it should have been 2.
91 No other assessment has been completed since
this assessment. The assessment is valid and has been accepted
by the ASAP. What do I do?
92 Three errors are found in Mr. T's Assessment;
A0310A = 1; and A0310B = 1. Incorrect SS#, Incorrect Gender &
M0300C = 0 (# of stage 3 pressure ulcers) when it should have been 2.
The assessment is valid and has been accepted by the ASAP database.
93 No other assessment has been completed since
this error. The interdisciplinary team determined this
was a significant error but no significant change in the resident's condition occurred.
What do I do?
94 The End. Please refer to the Answers section
handout to see how well you did with all questions.