MDS Alert

Published on Mon Apr 20, 2009 PDF

Find out what to expect with this major delay.

With rumors of an MDS 3.0 delay in play for months, the Centers for Medicare & Medicaid Services' official announcement that the instrument indeed wouldn't roll out on Oct. 1 hardly came out of the blue. But up until the March SNF/LTC Open Door Forum, CMS remained firm that the timeline was on track. Now the agency says implementation will occur in October 2010.

"The revised timeline is being reviewed internally," said CMS' Tom Dudley, MS, RN, in announcing the delay in the March 5, 2009 SNF/LTC Open Door Forum. CMS will post the revised timeline on its Web site at www.cms.hhs.gov and send the notice through the ODF list serve, he said. The data sets and items due to be released in March 2009 will "likely not be published until October 2009," Dudley added.

The good news is that everyone has more time now to address this major change for the industry, says Peter Arbuthnot, regulatory analyst for American HealthTech, a software developer in Jackson, Miss. "The bad news is that a lot of people had already started development and training and other processes to address the regulatory change" -- work that is now on hold.

"The delay wasn't a surprise, as there has been a lot of concern about the timeline for case-mix states and software vendors," says Sandra Fitzler, RN, senior director of clinical services for the American Health Care Association. And STRIVE hasn't been completed so we didn't know what changes that project will make to the MDS 3.0, she adds.

Another problem: "The October 2008 version of the MDS 3.0 posted by CMS included data elements that weren't in the previous draft developed by RAND and released in January 2008," adds Fitzler. And "RAND tested all MDS 2.0 data elements," omitting the ones from the January draft MDS 3.0 that researchers found weren't "reliable, valid or accurate." Thus, CMS will likely be considering the data element issues, as well as the impact of STRIVE on the MDS 3.0, she says.

Stay tuned: CMS is expected to unveil the new RUG system in the proposed SNF PPS update rule in the late spring. CMS is in the process of drafting its annual payment rule, and thus couldn't reveal anything at the March 5 ODF.

"We can't give you information on changes to the RUG system ... but a rule will be out soon that will give you detailed information," said the agency's Sheila Lambowitz.