I am looking for documentation from CMS related to changing PPS assessments after the
7 day edit/encoding period. There is a PPS consulting group in our area that requests
that the facility not transmit until they {the consultants}review. When the consulting
group determines that additional money could have been made by modification of the MDS
and/or changing the ARD, the facility is directed to complete a new MDS. This is done
after the R2b date and before transmission.
My group has concerns with this process:
1) Modifications to the MDS are done beyond the 7 day edit/encoding period.
2) Changing the ARD, sometimes weeks later, does not seem appropriate as it conflicts
with the missed assessment MDS policy. {Example: If you can't set the ARD date weeks
after the fact then you can't re-set the ARD either.} Second, the MDSs are then
technically completed (R2b) beyond 14 days from the ARD.
3) Temptation-they list your loss financially and the temptation to change the MDS is
strong (especially when the Administrator asks you to do it).
We are surprised that some major nursing home chains make a practice of this and that
a some experienced MDS coordinators have now adopted this practice. The rebuttal
includes "there is no financial penalty for completing assessments beyond 14 days from
the ARD". The RAI manual does not directly tell you that you can not to do this but it
seems implied by all the rules. We do not recommend this practice. Can anyone help me
to find CMS documentation related to the support or non-compliance of this practice?
Thanks very much.
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