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Our surveyors in CA cannot tell you that there is a State regulation or requirement for MDS. We have no State Requirements for MDS outside of the fact that CA 'agreed' to use the OBRA requirements after we sued HCFA because CA thought we did not have to follow the Federal requirements.
HCFA finally told CA that they had to comply, we were so close to the implementation date in 1991 that the state just said OK, use the forms and instructions from HCFA.
Definitely not a technical explanation--but close enough. You can and should hold our State surveyors or [in the case of LA County] County surveyors to the RAI Manual. Do not be intimidated by them, they are weak on Federal requirements.
Delores
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