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I must agree with Nathan on this one. If CMS
allows us to use section T to get proper payment for days of service - even if
the resident is discharged, I also believe it is CMS intent for us to get proper
payment by selecting the ARD as long as it falls within the proper reference
period. WHEN we select it is not the point here.
----- Original Message -----
Sent: Thursday, March 11, 2004 2:13
AM
Subject: Re: Changing PPS Assessments
weeks after R2B before transmission
You are correct. Once the window has
closed, it is not permitted to set the ARD back into the window. This is
CMS policy.
Rena
Rena R. Shephard, MHA, RN, FACDONA,
RAC-C
Chair, American Association of Nurse Assessment Coordinators
[EMAIL PROTECTED]
Subj: RE: Changing PPS Assessments weeks after R2B before
transmission
Date: 3/10/04 7:11:43 PM Pacific Standard Time
From:
[EMAIL PROTECTED]
Reply-to: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Sent from the Internet
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
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