I don't think you will get in any trouble for not counting the minutes on the MDS, but the reason for not doing so would probably cause some issues. At some point a surveyor is going to ask why you don't count the minutes on the MDS. If the facility says that you don't have enough staff to do it, I would expect some digging by the surveyors to see if you have enough staff to provide appropriate care. It just seems to create a red flag I would not care to create.
I assume that the care that is being provided is going into therapy or nursing notes just minus the minutes. You at least need to do that much.
Nathan Lake, RN, MSHA
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