On Sept. 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the draft MDS Nursing Home Comprehensive (NC) Item Set version 1.18.11 Nursing homes will be required to implement the v1.18.11 item sets—with their many changes—beginning Oct. 1, 2023.
Some significant changes include:
- Section G (Functional Status) will no longer exist! Some Section G items have been updated and incorporated into Section GG including two former Section G items, Functional Limitation in Range of Motion and Mobility devices. Assessment windows for some item sets will be adjusted.
- Section GG takes central stage and becomes critical to OBRA assessments and Interim Payment Assessments (IPAs). Those facilities who have relied heavily on therapy to assess and code Section GG are now behind those like Premier Therapy’s partners who have embraced the collaborative effort in coding usual performance and have focused on nursing training on coding of Section GG elements.
- Items that will accommodate the Transfer of Health Information QRP quality measures have been added.
- Items that will accommodate an additional five categories of Standardized Patient Assessment Data Elements (SPADEs) have been added.
- PHQ-9 was changed to PHQ-2 to 9, which could shorten the interview to two questions in some cases.
We will look for the release of the updated RAI manual for further information regarding the changes.
Premier Therapy and our partnering facilities have been training for this since 2017. We are ready for what’s to come. Are you?
The Q4FY21 release of the Skilled Nursing Facility (SNF) Program for Evaluating Payment Patterns Electronic Report (PEPPER) is now available. This newly updated version reflects recent changes made to more accurately highlight PDPM areas of concern.
PEPPER is an educational tool that summarizes provider-specific data statistics for Medicare services that may be at risk for improper payments. SNFs can use the data to support internal auditing and monitoring activities as part of their compliance program. The PEPPER Team does not provide PEPPERs to other contractors, although it does provide a Microsoft Access database to MACs and Recovery Auditors so areas of concern should be addressed.
The above PEPPER target areas were identified by CMS as being potentially at risk for improper Medicare payments. A high target area percent does not necessarily indicate the presence of improper payment or that the provider is doing anything wrong; however, under these circumstances, providers may wish to review their medical record documentation to ensure that the services their beneficiaries receive are appropriate and necessary, as well as to ensure that the documentation in the medical record supports the level of care and services for which they have received Medicare reimbursement.
The SNF PEPPER is available to the SNF’s Chief Executive Officer, Administrator, President, Quality Assurance and Performance Improvement Officer, or Compliance Officer through a secure portal on the PEPPER.CBRPEPPER.org website.
If you are concerned about outliers on your SNF PEPPER, ensure:
- therapy/nursing staff have the skills necessary to provide and document medically necessary treatments.
- a triple check system is in place that monitors therapy, MDS and billing for accuracy