but wouldn't choosing the ARD on day 9 already be outside the assessment window?? I thought you had only up to day 8 to set the date??
Tammy Gola BSN, RN, CRNAC Wilkes-Barre General Hospital Transitional Care Unit 575 North River Street Wilkes-Barre, PA. 187641-0001 570-552-5417 [EMAIL PROTECTED] -----Original Message----- From: Nathan [mailto:[EMAIL PROTECTED] Sent: Wednesday, March 10, 2004 10:59 AM To: [EMAIL PROTECTED] Subject: Re: Changing PPS Assessments weeks after R2B before transmission Becky said... Then Nathan, how do you justify the sentence in the RAI Manual that says "A late or missed assessment may be completed as long as the window for the allowable ARD (including grade days) has not passed". If you wait until day 9 or 10 aren't you passed the "window"? First, that sentence does not appear to make any sense as written. If the window has not passed (e.g. day 8 for a Medicare 5 day) how is the assessment late or missed? Nothing is late at that point. I believe this sentence was meant to say that an assessment can be completed late as long as the ARD falls within the allowable window. This would tie in more closely with the very next sentece which states, "If a late/missed assessment has an ARD within the allowable grace period, no financial penalty is assessed." This sentence supports what I am claiming. To me that means you can be late with part of the assessment as long as the ARD falls within the allowable range. You can be late with R2b, VB2, VB4, AND late choosing an ARD. The only reason for assessment financial penalties is an ARD outside the allowable range. So, you admit a resident on day 1. On day 9 you select your ARD. On day 12 you complete the assessment (R2b). On day 14 you complete the RAPs and the careplan (VB2 and VB4). On day 16 you submit. I just don't see a problem with that. None of the dates are fraudulent. None of the date are out of regulatory compliance. It looks good to me...except that the general acceptance is you can't do it. I have asked CMS to address this on a number of ocassions and have gotten nothing back. Maybe they are listening. Nathan ----- Original Message ----- From: rlabarge (Becky <mailto:[EMAIL PROTECTED]> LaBarge) To: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> Sent: Wednesday, March 10, 2004 6:23 AM Subject: RE: Changing PPS Assessments weeks after R2B before transmission Then Nathan, how do you justify the sentence in the RAI Manual that says "A late or missed assessment may be completed as long as the window for the allowable ARD (including grade days) has not passed". If you wait until day 9 or 10 aren't you passed the "window"? -----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. Nathan ----- Original Message ----- From: dawn <mailto:[EMAIL PROTECTED]> To: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> 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 ----- From: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> To: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> 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] <mailto:[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 Confidentiality Notice: This e-mail message including attachments, if any, is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please notify this office immediately. /---------------------------------------------------------- The Case Mix Discussion Group is a free service of the American Association of Nurse Assessment Coordinators "Committed to the Assessment Professional" Be sure to visit the AANAC website. Accurate answers to your questions posted to NAC News and FAQs. For more info visit us at http://www.aanac.org -----------------------------------------------------------/
