There is soooo much disinformation about the changes that occurred on October 1st, we have put together a brief Answer Sheet for MDS 3.0 and RUG IV

This page will be updated as we get questions specifically on MDS 3.0 and RUGs IV

Disclaimer: We attempt to provide the most up to date information to our visitors. As regulations can change, the information provided is current as of the date of publication. As changes occur, we will always attempt to keep this page as current as possible. Readers are responsible for the interpretation of the regulations and the appropriate completion of the MDS. Encompass is providing this information as a service and does not take responsibility for inappropriate Medicare Compliance. as always, the provider should use appropriate legal resources as appropriate.

Use of Grace Days is a Red Flag: December 13th 2010

Therapy must see the patient on the day of admission otherwise the facility will be paid at the default rate: October 1st 2010

The answer is exactly the same as under MDs 2.0. Grace days are to be used when appropriate; consistent use of grace days for every patient would be a red flag. The most frequent use of grace days are with the 5 day assessment as, with the elimination of the old section T allowing a prediction to create the therapy RUG level, therapy services must now be provided at the appropriate level to create the RUG IV reimbursement. Because of the fact that 5 days of therapy required, and seeing the patient on the day of admission is not appropriate for every patient, use of grace days becomes inevitable.

Recognizing this, the RAI Manual addresses this situation in Chapter 2 when it identified that there are three reasons that Grace days can be used.

1. Illness of the RN assessor

2. A high volume of MDS assessments that are due at the same time

3. To capture additional days necessary to more fully capture therapy or other treatments

Remember! The purpose of the MDS is to collect the most appropriate information of the patient's need in order to reimburse the facility appropriately, for the care that the patient needs.

There has been so much confusion over this and unfortunately, there are many "consultants" out there who are adding to this. This misunderstanding has arisen from two situations;

a) The transitional period which is already in place where a patient is in an observation period that is part prior to Oct 1st and part after Oct 1st. This is requiring the facility to complete both the MDS 2.0 and 3.0 for the appropriate period or they may choose to take a default rate for days covered by one of the assessments.

b) The elimination of section T and the ability to predict a patient into a RUG category. The patient must either have a minimum of 5 therapy days within the period (or 3 therapy with 6 days restorative) to achieve a rehab RUG OR if the patient is discharged before day 8 and therapy has not seen the patient enough time to create the RUG, then a short stay assessment is submitted (a combination of the 5 day PPS MDS and the start of therapy OMRA). The short stay assessment has certain criteria that must be met in order to achieve the rehab payment, and seeing the patient on day one, in these situations may actually hurt the facility rather than helping.

Remember: The therapy evaluation and creating of the POT should provide the most accurate reflection of the patient's actual need. Medicare DOES NOT have a requirement that the patient bee seen either on the day of admit or within 24 hours. If the patient is not stable enough to evaluate AND treat on the day of admission, then wait till the next day. THERE will NOT be a DEFAULT rate paid for this determination.