Medicare Releases Last Minute Clarificatinos to MDS 3.0 Section O400.
Just when you thought your new procedures were in place for MDS 3.0, Medicare drops a bombshell. On September 23, 2010, CMS released updates and clarifications to several sections of the MDS 3.0, including O400 Therapies.
In the document https://www.cms.gov/NursingHomeQualityInits/downloads/MDS30Chapter3SectionOPageo-17Errata.pdf at the bottom of page O-17, CMS states “For purposes of the MDS, when the payer for therapy services is not Medicare Part B, follow the definitions and coding for Medicare Part A.”
If you are in a case-mix state, CMS just dictated how you must manage your Medicaid caseload, 8 days before the new system begins. Does your company have systems in place to schedule, treat, and track modes of therapy for your Medicaid caseload in the same manner as Medicare A? If you were planning on treating your Medicaid residents concurrently after October 1, 2010, you will have great difficulty capturing the frequently targeted Rehab-Medium RUGS IV score on the patient’s quarterly assessment. Concurrent therapy minutes will be divided by 2 once entered into the MDS, so 150 concurrent minutes will net just 75 minutes in the MDS.
If you work in a case-mix state, you will need to schedule group and individual minutes for your Medicaid caseload, as if they had Medicare A, in order to efficiently capture targeted RUGS levels.