MDS Alert

RAI Compliance:

Use A Compliant Timeline For A Combined OBRA Admission And 5-Day PPS Assessment

Meet RAI requirements and capture fair payment.

Talk about a juggling act: The following example shows how you can meet deadlines for the OBRA-required admission assessment--and strategically manage the assessment reference date for the 5-day MDS.

You have the option, of course, of combining the Medicare 5-day or 14-day assessment with the OBRA comprehensive admission assessment. In this case, the SNF decides to use the 5-day MDS for a new rehab patient who is admitted to the facility on a Saturday.

Be flexible: Always using the 5-day MDS for the admission assessment will make staff do extra work for residents who leave before the 14-day assessment is due. But if you always use the 14-day MDS assessment for the admission assessment, you lose the flexibility of using grace days to provide more therapy, for example, to put someone in ultra high rehab, says Marilyn Mines, RN, BC, RAC-C. The latter would pay more than setting an earlier ARD to capture the IV medication in the hospital lookback for extensive services plus rehab, she notes.

For this 5-day assessment, the team sets the ARD for day 7.

Rationale: They select that day because the physician discontinued the resident's "extensive service qualifier" on the day of admission to the facility, says Mines. And "therapy wasn't going to be in to evaluate" the resident until Monday. The MDS nurse might review the MDS and sign R2b on day 12, giving all disciplines time to complete their sections, Mines suggests. "On day 13 or 14, the team members do the RAPs," and the MDS coordinator signs off at VB2, indicating the RAP process is complete, by day 14. The RAI rules require the care plan completion date (VB4) to be seven days after VB2, which would be day 21.

Transmit the MDS to the state within 31 days of the care plan completion date at VB4.

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