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 LaBarge)
To: [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
To: [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]
To: [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] 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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