2.1 Introduction to the Requirements for the RAI

It is important to note that when the OBRA and PPS assessment time frames coincide, one assessment may be used to satisfy both requirements. In such cases, the most stringent requirement for MDS completion must be met. Therefore, it is imperative that nursing home staff fully understand the requirements for both types of assessments in order to avoid unnecessary duplication of effort and to remain in compliance with both OBRA and PPS requirements. (Refer to Sections 2.10 and 2.11 for combining OBRA and PPS assessments)

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Change in Ownership:-Assume the Assets and Liabilities

 

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    Change in Ownership:

    • There are two types of change in ownership transactions:
      • — The more common situation requires the new owner to assume the assets and liabilities of the prior owner and retain the current CCN number.
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      • In this case: ○
        • The assessment schedule for existing residents continues, and the facility continues to use the existing provider number. ○
        • Staff with QIES user IDs continue to use the same QIES user IDs. ○
        • Example: if the Admission assessment was done 10 days prior to the change in ownership, the next OBRA assessment would be due no later than 92 days after the ARD (A2300) of the Admission assessment and would be submitted using the existing provider number. If the resident is in a Part A stay, and the 5-Day PPS assessment was combined with the OBRA Admission assessment, the next PPS assessment could be an Interim Payment Assessment (IPA), if the provider chooses to complete one, and would also be submitted under the existing provider number.
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    2.1 Introduction to the Requirements for the RAI

    MDS assessments are also required for Medicare payment (Skilled Nursing Facility (SNF) PPS) purposes under Medicare Part A (described in detail in Section 2.9) or for the SNF Quality Reporting Program (QRP) required under the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).

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    2.1 Introduction to the Requirements for the RAI

    The OBRA regulations require nursing homes that are Medicare certified, Medicaid certified or both, to conduct initial and periodic assessments for all their residents. The Resident Assessment Instrument (RAI) process is the basis for the accurate assessment of each resident. The MDS 3.0 is part of that assessment process and is required by CMS. The OBRA-required assessments will be described in detail in Section 2.6.

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    uses of the MDS- Expanded- Access to Nursing Home Information

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    Consumer Access to Nursing Home Information.

    Consumers are also able to access information about every Medicare- and/or Medicaid-certified nursing home in the country. The Nursing Home Compare tool (www.medicare.gov/nursinghomecompare) provides public access to nursing home characteristics, staffing and quality of care measures for certified nursing homes.

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    uses of the MDS- Expanded-Monitoring

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    Monitoring the Quality of Care. MDS assessment data are also used to monitor the quality of care in the nation’s nursing homes. MDS-based quality measures (QMs) were developed by researchers to assist: (1) State Survey and Certification staff in identifying potential care problems in a nursing home; (2) nursing home providers with quality improvement activities/efforts; (3) nursing home consumers in understanding the quality of care provided by a nursing home; and (4) CMS with long-term quality monitoring and program planning. CMS continuously evaluates the usefulness of the QMs, which may be modified in the future to enhance their effectiveness

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    uses of the MDS- Expanded-Payment

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    Medicare and Medicaid Payment Systems. The MDS contains items that reflect the acuity level of the resident, including diagnoses, treatments, and an evaluation of the resident’s functional status. The MDS is used as a data collection tool to classify Medicare residents into PDPM components. The PDPM classification system is used in SNF PPS for skilled nursing facilities and non-critical access hospital swing bed programs. States may use PDPM, a Resource Utilization Group-based system, or an alternate system to group residents into similar resource usage categories for the purposes of Medicaid reimbursement. More detailed information on the SNF PPS is provided in Chapters 2 and 6. Please refer to the Medicare Internet-Only Manuals, including the Medicare Benefit Policy Manual, located at https://www.cms.gov/Regulations-and Guidance/Guidance/Manuals/index.html for comprehensive information on SNF PPS, including, but not limited to, SNF coverage, SNF policies, and claims processing.

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    Use of Minimum Data Set (MDS)- Primary -Comprehensive Assessment

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    [MDS has]   core set of screening, clinical, and functional status elements, including common definitions and coding categories, which forms the foundation of a comprehensive assessment for all residents of nursing homes certified to participate in Medicare or Medicaid.

    • The items in the MDS standardize communication about resident problems and conditions within nursing homes, between nursing homes, and between nursing homes and outside agencies. The required subsets of data items for each MDS assessment and tracking document (e.g., Comprehensive, Quarterly, OBRA Discharge, Entry Tracking, PPS item sets) can be found in Appendix H.
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    Care Area Assessment (CAA) Process

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    • This process is designed to assist the assessor to systematically interpret the information recorded on the MDS. Once a care area has been triggered, nursing home providers use current, evidence-based clinical resources to conduct an assessment of the potential problem and determine whether or not to care plan for it. The CAA process helps the clinician to focus on key issues identified during the assessment process so that decisions as to whether and how to intervene can be explored with the resident. The CAA process is explained in detail in Chapter 4. Specific components of the CAA process include:
      • Care Area Triggers (CATs) are specific resident responses for one or a combination of MDS elements. The triggers identify residents who have or are at risk for developing specific functional problems and require further assessment.  
      • Care Area Assessment is the further investigation of triggered areas, to determine if the care area triggers require interventions and care planning. The CAA resources are provided as a courtesy to facilities in Appendix C. These resources include a compilation of checklists and Web links that may be helpful in performing the assessment of a triggered care area. The use of these resources is not mandatory and the list of Web links is neither all-inclusive nor government endorsed.
      • CAA Summary (Section V of the MDS 3.0) provides a location for documentation of the care area(s) that have triggered from the MDS and the decisions made during the CAA process regarding whether or not to proceed to care planning
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