Closeup of nurse making notes near patient's bed

Major changes to resident assessment tools, increasing quality reporting requirements and new state Medicaid payment tools will continue to dog providers well into 2024, a trio of clinical and reimbursement experts warned Wednesday.

A series of struggles around assessment began in fall, with the most extensive updates in years to the Minimum Data Set, which captures patients’ clinical needs and also serves as the basis for much of a provider’s state and federal reimbursement.

“It’s not news to anybody that this rollout was not smooth,” said Alicia Cantinieri, senior vice president of Clinical Policy and Education for Zimmet Healthcare Services Group. “There were a lot of technical issues with coding, with skip patterns, with Section GG, with HIPPS code calculation being incorrect.”

Despite the Centers for Medicare & Medicaid Service issuing corrections and technical clarifications in the weeks after the Oct. 1 launch of the updated MDS, some providers still may face long-term consequences of coding errors or delays forced on them by incomplete early guidance from regulators. That was just one of the cautions shared by Cantinieri and two of her Zimmet colleagues during a webinar titled, “Fasten Your Seatbelts: It Might be a Bumpy Ride.”

Cantinieri said the lasting implications of some software and coding issues in the first week of the launch were going to especially affect providers in states that used the Patient Driven Payment Mode to determine a Medicaid case-mix before the changeover.

In the case of providers who needed to code patients receiving respiratory therapy, for example, many found the section blocked out and were unable to capture payment for related services. Some went back and modified submission; others waited to submit until they had clarification on how to correct the problem.

“Facilities have been left with questions about when to modify, when to resubmit,” she added. “And we haven’t heard any guidance from CMS that they would waive or forgive the submission timing requirement, so there’s the potential that facility could be cited.”

Chief Innovation Officer Steven Littlehale said that regardless of the complication or system error, it is critical that providers keep related records for a few years “so that ultimately you’re not left holding the bag for this sort of failed launch.”

Duplication of efforts

The removal of Section G to measure a patient’s functional status also continues to wreak havoc on payment, especially at the state level. Many states used G to determine payments, and without it, complications have continued to crop up, said Melanie Tribe-Scott, vice president of Quality and Regulatory Compliance.

For providers in many states not using the PDPM yet, the workload has increased significantly, with many requiring that MDS coordinators record information in the replacement Section GG and capture details for all patients on an optional state assessment, too.

The advent of MDS also has led to frozen pay in some states, while upcoming quality measure changes will lead to freezing quality measures as well, the speakers noted. That may discourage providers from being diligent in some areas, thinking they are temporarily less important.

But that couldn’t be farther from the truth for payment, Tribe-Scott added. She said some states would undoubtedly be using codes captured in the frozen period to see how provider behavior and patient needs would shape spending under a system more aligned with PDPM.

And those frozen metrics, which lock in April to give regulators more time to collect full data before publishing new calculations, also could come back to haunt if not given enough attention. Most are connected to new quality measures, which will be used later to inform quality measure ratings on the Care Compare website.

“Eventually, it will be thawed and you’ll see those new measures,” Littlehale said. “It’s important to not turn your back, for quality improvement reasons, on those very outcomes. You need to get a little old school with how you’ve tracking performance in those areas.”

Stay ahead of problems, and no blanking out

Another critical change is coming Jan. 1: Providers will need to submit a higher percentage of MDS data than in years past to remain eligible for a value-based purchasing payment bump. It’s critical they not leave boxes blank, especially new ones, simply because staff don’t understand how or when to complete them, Cantinieri said.

Providers can stay ahead of some of the challenges by taking a few steps as 2024 gets underway, the presenters said.

Cantinieri recommended auditing MDS forms to make sure information is being collected and submitted correctly; a standard size nursing home could make it a quality improvement goal to review 10 charts per month and include charts from a variety of patients involving a range of interdisciplinary staff. An external audit also could benefit providers who want to ensure they’re capturing everything possible in line with the Oct. 1 changes.

The team also suggested reaching out to any MDS-involved software vendors to ensure updates have been made and that any incorrect data caused by early adoption kinks has been retroactively corrected, if appropriate.