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October 1, 2023 MDS changes survival guide – The rule of 3s

In situations of survival, there is the “rule of 3s,” which involves the priorities to survive. You can survive for 3 minutes without air, 3 hours without shelter, 3 days without water and 3 weeks without food. However, with the right preparation, you can help place the odds in your favor of not only surviving – but thriving.

October 1st is not far away. In keeping with the spirit of “survival” in this challenging time you must prepare and prioritize. In this blog I will highlight 3 major changes, 3 ways to prepare, and 3 steps to help ensure seamless compliance once that day arrives.

Collaborating with your technology vendor is key

October 1st brings the most profound number of changes to MDS in over 10 years. Reimbursement areas impacted include Care Area Assessment (CAA), individualized care planning, discharge planning, surveys, SNF Quality Reporting Program (QRP) and Five Star ratings. Most importantly, the changes will impact the quality of care you deliver to your residents.

If you’re not prepared, these changes could be scary. However, with advance planning and collaboration with your technology vendor, the road to October 1st does not have to be a lesson in survival.

Three major changes coming your way

  1. Section G has been removed and merged with Section GG (Functional Abilities and Goals)
    1. With Section G (Functional Status) removed from the MDS, facilities will be unable to calculate a RUG score.
    2. CMS has not yet officially released a replacement and is allowing states to have Section G and GG running at the same time, in what CMS calls an optional state assessment (OSA) until 9/30/2025 (See #3).
    3. This breaks the connection to other functionalities, setting off a string of disruptions.
    4. Everyone who knows RUGs understands the importance of bed mobility, transfer, toilet use, eating and the results of the ADL calculation. Based on the draft forms, which included the Comprehensive, Quarterly, PPS and Discharge, there will be no path to producing a valid RUG score.
    5. There will be impact QMs and changes to the Five-Star reporting program calculations.

  2. Section A will have new SDOH data points
    1. The current administration has placed a high emphasis on advancing health equity. With this comes the expansion of information gathering on SDOH, including enhanced race and ethnicity data points.
    2. New items have been added to determine more specifically a resident’s race and ethnicity and meet new QRP (Quality Reporting Program) and SPADEs (Specialized Patient Assessment Data Elements) for social determinants of health.
    3. Six (6) new categories of SPADEs data will be collected on admissions and discharges beginning October 1st, 2023:
      1. Ethnicity
      2. Race
      3. Language
      4. Transportation
      5. Health Literacy
      6. Social Isolation
  1. The OSA: To use or not to use, that is the question
    1. Use of the Optional State Assessment (OSA) makes information available to maintain legacy Resource Utilization Group (RUG) systems.
    2. Each state determines whether the OSA is required and when it must be completed.
    3. Some states are continuing the use of the OSA.
    4. Some states will transition to PDPM.
    5. The OSA is due to be phased out by CMS by October 1st,
    6. MatrixCare customers have access to an up-to-date list of states using RUGs or PDPM, here.

Three ways to prepare for the changes

  1. Review
    1. Access available resources in the MatrixCare Community here.
    2. Gather your IDT (Interdisciplinary Team) members included in the RAI (Resident Assessment Instrument) process and review the final item sets within the draft RAI manual.
    3. This will give way to reevaluation of facility policies and data collection forms.

  2. Educate
    1. The first role to focus on is the caregiver’s role, including nursing or other direct care clinical staff. Identify staff competencies and those most appropriate to answer GG questions.
    2. The second critical role is the dedicated educator role. Create a mandatory, targeted, training plan now.
    3. The 3rd significant role, one which leads to overall success, is the MDS Coordinator. Rely on them to identify which forms, observations, or assessments need to be updated based on the new regulations.
    4. Attend CMS MDS 3.0 v1.18.11 Trainings here.

  3. Implement
    1. Train IDT members and staff on upcoming changes/updates
    2. Ask questions!
      1. With the addition of social determinants of health to the MDS, who will collect it and how will they do it?
      2. Will CNAs collect section GG data?
      3. Without section G, what will trigger Care Area Assessments (CAAs)?
      4. How will CMS adjust five-star rating calculations?

Three steps to ensure compliance

As October 1st approaches, your EHR vendor will want to ensure that you not only survive but thrive. They are your partners in this regulatory “adventure.”

  1. Communicate
    1. Ask
      1. What have they done to date to prepare?
      2. Where can you find the latest information?
      3. What webinars/recordings will be available?
      4. What product training are they offering?
    2.  Inform
      1. Let your vendor know what you are hearing at your state level about RUGs vs PDPM.
      2.  Educate
        1. What is their education plan (webinars, sessions, whitepapers)
        2. When will updated MDS questions, forms, observations, and events be released.

  2. Coordinate
    1. Have your vendor point you to their experts, consultants, trainers, and thought leaders – people who translate in “non-techy” long-term care friendly terminology, what the upcoming changes will mean for their EHR solution and most importantly for your organization.

  3. Collaborate
    1. Participate in beta testing opportunities, training and demos.
    2. Test drive in your training or testing environment by adding an MDS with dates after October 1, 2023, so you can see the MDS updates for a hands-on experience and prepare for your internal educational needs.

The time to plan your strategy for surviving October 1st is now

Do not let what is coming intimidate you or your staff. Any experienced survivalist will tell you that the key to success in any situation is another rule of three: stay calm, establish your priorities and make a plan.

Planning for dramatic change is never easy, but with proper preparation and partnering with the right technology vendor, you can win the day.

Request a demo today for a closer look at MatrixCare.

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Jenny Lee

Jenny Lee is a health care regulatory expert with more than 15 years of experience. After working for the Brookings Institution and various specialty medical organizations, including ASCRS and the National PACE Association, she joined MatrixCare as its Regulatory Compliance Manager, to ensure that all its technology solutions remain compliant in the ever-changing health care market. She is excited by MatrixCare’s continuous opportunities for innovation to support patients and providers in the long-term care space.

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