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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
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- Changing PPS Assessments weeks after R2B before... hynesassociates
- Re: Changing PPS Assessments weeks after R... Nmcb40doc
- RE: Changing PPS Assessments weeks after R... Winona M. Phelps
- RE: Changing PPS Assessments weeks after R... hynesassociates
- RE: Changing PPS Assessments weeks after R... rlabarge \(Becky LaBarge\)
- RE: Changing PPS Assessments weeks after R... Orth, Ron A
- RE: Changing PPS Assessments weeks after R... Winona M. Phelps
- RE: Changing PPS Assessments weeks after R... Gola, Tammy
