I must weigh in on my favorite subject. I agree that the standard interpretation of the rules says this is not allowed, but I have always argued it should be allowed - with one caveat. I believe the facility should be able to change the ARD up until the point of submission (lock) as long as they change the R2b date when they make the ARD change. Think about it. For one, how would this be fraud or cost the government any money they do not owe the facility? Take this scenario:
 
The resident is admitted on January 10 after a 10 day hospital stay. You collect as much information as possible from the hospital, and immediately begin documenting everything related to any PPS item that occurs in your facility. You are going to do full data collection for 8 days. Remember, this is only hypothetical. That means that on day 9 you can look at each of the first 8 days and know how you would answer every MDS item if that day was the ARD. The team sits down on day 9 or 10 and reviews all this data. To take it to an extreme, you might do 8 different Medicare 5 day assessments each with a different ARD and view the results. The team decides that choosing day 7 gives an assessment that best represents the care being delivered to the resident. They complete the assessment and put day 10 as the R2b. The next day (day 11) the PT says the documentation for the rehab minutes was incorrect Based on the new information, the team decides to change the ARD to day 8 and they change the R2b to day 11.
 
The only difference between this scenario and the way it is normally done is that this does not make you guess at the impact of the day you choose. You know for a fact what the outcome will be since you have all the data in front of you. There is no fraud. You are honest in your documentation, honest in your R2b date and you are making the right choice for reimbursement.
 
 
A second point - regardless of whether you do things in the normal way, or the way I presented, the burden is still on the facility to make sure the data in the assessment is accurate for the chosen ARD. In the end, there should be no difference between the two assessments other than the normal differences that occur due to changes in the ARD.  Facilities that do things this way probably have better data collection than those that just pick a day in the heat of battle.
 
Nathan
 
----- Original Message -----
From: dawn
Sent: Tuesday, March 09, 2004 2:54 PM
Subject: Re: Changing PPS Assessments weeks after R2B before transmission

 
 
 
This is not good......I agree uh oh
 
----- Original Message -----
Sent: Monday, March 08, 2004 9:21 PM
Subject: Re: Changing PPS Assessments weeks after R2B before transmission

In a message dated 3/8/2004 6:11:20 PM Pacific Standard Time, [EMAIL PROTECTED] writes:
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.
uh oh

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