I have to agree with Nathan on this
one. It never has made sense why a facility cant wait until after the
assessment window to pick the best ARD date. As long as the ARD is within
the first 1-8 days (for the 5--day) what difference does it really make to CMS
whether that date was picked on day 8, or more appropriately it was chosed after
the entire assessment window has passed to ensure the best appropriate ARD and
RUG.
Ron
-----Original Message----- From: Nathan
[mailto:[EMAIL PROTECTED] Sent: Tuesday, March 09, 2004 5:53
PM To: [EMAIL PROTECTED] Subject: Re: Changing PPS
Assessments weeks after R2B before transmission
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.
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.
