7/1/2011 EVERYTHING YOU NEED TO KNOW TO SUCCEED WITH THIS NEW PROCESS ABOUT LEAH I FOCUS ON LEARNING, NOT TEACHING
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1 BIP-PITY BOB-PITY BOO!!!!!! MAKE THE MDS 3.0 WORK FOR YOU IT IS NOT MAGIC!!!!!! Leah Klusch, RN, BSN, FACHCA EVERYTHING YOU NEED TO KNOW TO SUCCEED WITH THIS NEW PROCESS ABOUT LEAH I FOCUS ON LEARNING, NOT TEACHING Leah Klusch is the founder and the Executive Director of the Alliance Training Center. As an educator and consultant, she has extensive experience in presenting motivating programs on operation issues for individual ownership groups, facility managers, state, regional, and national associations Leah & RediLearning have partnered to provide an exclusive, comprehensive MDS 3.0 Program available ONLINE and accessible anytime! This program will be shown in this presentation via a live demo! 1
2 Staffing changes in the MDS office POTENTIAL ISSUES IMPACTING CLINICAL MANAGERS RELATED TO MDS 3.0 Changes in the IDT Changes in policies and procedures MDS completion issues transmission issues validation issues painful billing issues What do our clinical staff need to learn about the new assessment process, definitions and documentation. Assessments out of compliance influence regulatory risk and signal the survey process AWARENESS & KNOWLEDGE ARE KEY Know the status of these issues in your facility The MDS manager may be busy and not want to disclose all the issues. Interact with the process and the staff Better to know the truth than to be surprised. *If assessments are not correct, in sequence and on time, they will not be validated and the services can not be billed and the facility may face regulatory risk. EVALUATE HOW THE MDS 3.0 ASSESSMENT PROCESS IS MANAGED MDS Assessments and management of the process is not a nursing responsibility At the beginning of the process in 1987, the assessment was nursing assigned and was not interdisciplinary Now the MDS 3.0 process is much larger than a clinical assessment and the responsibilities of the MDS Manager are very operational and interdisciplinary. Operational and clinical managers need to discuss the structure of the assessment process, team members assignments and performance and proper delegation of tasks as well as accountability. Payment and regulatory implications for Nursing Leadership 2
3 DO YOU KNOW How many MDS assessments are done in your facility by the day/month or by clinical units? Types of assessments that are being completed? The members of the IDT that are doing assessment tasks? The number of interviews by type that are being completed by the day or week? The number of submissions that are not validated on the first attempt? The reason why assessments are completed late ask the MDS Manager. The impact of mistakes on the MDS data set on payment for the facility? EVALUATING THE IMPACT OF MDS 3.0 Many Operational Staff Have NOT evaluated the impact of the change to the new data set on operational stability. They still believe the MDS process is a nursing task.. WRONG! They never evaluated the accuracy and efficiency of the MDS 2.0 so they were loosing money before. Data was not utilized properly by managers to assess outcomes, track patterns of care or validate payment EVALUATING THE IMPACT OF MDS 3.0 Software should be able to generate many reports that will isolate problems and identify patterns of care and outcomes Staffing habits and documentation tools were not substantiating the data = big risk on audit. Staff didn't t have resources / training to complete assessments accurately. This is a very important issue. Rehab services were not evaluated for documentation accuracy. Now we have a new process, new data set and definitions in place, which requires a change in the processes and knowledge base of our staff and our documentation tools. 3
4 CHANGES NEEDED FOR A SUCCESSFUL ASSESSMENT AND DATA BASE DEVELOPMENT PROCESS Operational and clinical leadership must manage the transition to the MDS 3.0 and identify the changes necessary to minimize payment and regulatory risk.: Budgetary Management Decisions Staff Delegation Policy Changes THE REALITY OF THE MDS 3.0 New database to identify care delivery patterns, services, resident characteristics, payment triggers and outcome measures. New format and structure to the assessment process including many new assessment formats. Completion time up 35%!! Many new tasks interviews and new documentation. Changes in definitions that drive the documentation and regulatory process. New software for all providers with a larger data base and more hardware requirements for efficiency. Training for managers. THE TRANSITION TO THE MDS 3.0 Investment in training, resource materials and support services. New tasks and schedules for data collection and reporting. Payment system change with more complex data processes and frequent payment loss for providers. New QI/QM data base to be released after the system is in place. April
5 THE TRUTH ABOUT THE MDS 3.0 Revised ADL scoring and calculation as well as ADL ranges.. (Now 0 16 ADL scale) New definitions Section G Increased regulatory definition.. Section J Falls Section P Restraints Section H Toileting programs Staff awareness and documentation formats must be revised to fit the assessment process. New payment system for Part A Medicare with new qualifiers and many changes in groupers. MANY OF THESE CHANGES REQUIRE YOU TO LOOK AT YOUR PROCESSES, FORMS, POLICIES AND PROGRAMS WHAT PAIN ARE YOU FEELING NOW? 1, Are the assessment documents being. completed, transmitted and validated on time? This is a big risk 2. Software performance Is your new MDS 3.0 software functioning and tracking assessment data properly? Can you retrieve data for reports? 3. Is the staffing that you currently have for assessment tasks adequate? Who has had specific training? 5
6 WHAT PAIN ARE YOU FEELING NOW? 4. Have you projected the changes to the payment rates or payment groupings that will occur after the transition. Evaluate RUG distribution not just total revenue. 5. What changes will impact your Medicaid payment rates case mix. 6. Have there been staffing changes? How are you managing the training of new staff and front line professionals? Training deficit will be expensive Keep records of competency and training. LETS LOOK AT THE ISSUES FROM A 40,000 FOOT VIEWPOINT.. CMS has created a new assessment process and data base that connects to a new Medicare payment system. The purpose for many of the changes is to improve oversight and reduce payment to the facilities OUCH!! The new process requires all new resource and processing systems which send data to a central server for validation, processing and storage. THIS REQUIRES PREPARATION AND PROACTIVE MANAGEMENT CMS did not handle the transition to the new process well Training began in April and has been continuous until now training must continue. The manual and process changed in that time requiring retraining and new resources. The transition has required investment and budget. Leadership and problem solving has been necessary from many levels. Monitoring of the data process and support to the staff doing the assessments is necessary. 6
7 STAFF SUPPORT IS CRUCIAL 1. Know who the primary players in the assessment and documentation process are Do they understand what they need to do and have the support from the IDT and operational staff to complete the assessments on time correctly..? 2. Understand that training does not mean learning Much of the early training was incomplete Many changes after July Training with competency testing is the best. Document training specifics. PRIMARY STEPS Identification of the assessment activity in the facility is essential. Medicare and Other assessments need to be tracked to monitor the process for efficiency and accuracy. Who is involved in the data collection and formulation process as well as transmission and billing. Evaluation of Compliance Very important Who knows the rules? Who uses the manual. MANUALS MUST BE IN NUMEROUS LOCATIONS IN THE FACILITY AND BE A CENTRAL REFERENCE FOR STAFF UNTIL THEY ADAPT TO THE NEW DEFINITIONS AND ASSESSMENT PROCESS. 7
8 QUESTIONS TO ADDRESS Who is managing the RAI or assessment process in the facility? What is their training, preparation, and understanding of the process and its requirements? Ask them what the changes are that they are dealing with you may be surprised with the answer you get. Who is doing interviews? What is their training and where are they documented in the record? Interviews must be conducted using the Steps for Assessment in the RAI Manual. Check it out. MANAGING PAYMENT How do you manage and document RUGs distribution prior to and after? What are the predictable changes and the real changes in RUG groupers and payment levels. Do you understand RUG IV payment and the changes in the CMI levels, payment levels and ADL coding? ADL CHANGES BIG DEAL! Changes will be seen in: 1. Definitions 2. Total number of codes utilized for calculation of the ADL score. 3. The calculator new values and lower ADL scores for common levels of support. 4. New ADL ranges for payment categories. 8
9 HOW ACCURATE ARE YOUR ADL SCORES? Are they documented in the record? How about those interviews with staff? START AT THE SOURCE What is the documentation behavior of your front line care givers? History, Forms, & Formats Just imagine they had the CMS checkbook and were writing the facilities reimbursement checks Far fetched? NO! Do you know the ADL scores for your Part A Medicare cases and your total census? How about ADLs for Rehab cases over time! Are ADL scores discussed at the Medicare Meeting? This is necessary! A FEW FACTS ABOUT ADL SCORES All MDS data sets create an ADL score for that resident during the assessment reference period. ADL scores distribute payment within payment categories. ADL calculation from the MDS 2.0 system to the MDS 3.0 system has been changed resulting in lower relative scores. 9
10 2.0 TO 3.0 ADL SCORE CALCULATION MDS 2.0 ADL Calculation Bed Mobility 2 2 ADL Pts 3 Transfer 2 2 ADL Pts 3 Eating 1 1 ADL Pts 1 Toilet Use 2 2 ADL Pts 3 MDS 3.0 ADL Calculation Bed Mobility 2 2 ADL Pts 1 Transfer 2 2 ADL Pts 1 Eating 1 1 ADL Pts 0 Toilet Use 2 2 ADL Pts 1 Total ADL Score = 10! Total ADL Score = 3! 2.0 TO 3.0 ADL SCORE CALCULATION MDS 2.0 ADL Calculation Bed Mobility 3 2 ADL Pts 4 Transfer 3 2 ADL Pts 4 Eating 1 2 ADL Pts 1 Toilet Use 3 2 ADL Pts 4 MDS 3.0 ADL Calculation Bed Mobility 3 2 ADL Pts 2 Transfer 3 2 ADL Pts 2 Eating 1 2 ADL Pts 2 Toilet Use 3 2 ADL Pts 2 Total ADL Score = 13! Total ADL Score = 8! 2.0 TO 3.0 ADL SCORE CALCULATION MDS 2.0 ADL Calculation Bed Mobility 3 3 ADL Pts 5 Transfer 3 3 ADL Pts 5 Eating 1 1 ADL Pts 1 Toilet Use 3 2 ADL Pts 4 MDS 3.0 ADL Calculation Bed Mobility 3 3 ADL Pts 4 Transfer 3 3 ADL Pts 4 Eating 1 1 ADL Pts 0 Toilet Use 3 2 ADL Pts 2 Total ADL Score = 15! Total ADL Score = 10! 10
11 WHAT IT MEANS FOR YOU First you must identify the documentation process and the requirements of ADL performance and support provided by your staff to determine if the ADL scoring in the MDS data set is accurate Second you must monitor ADL levels in the facility data base and on a case by case basis. IMPORTANT QUESTIONS.. 1. Which members of your IDT and Rehab staff understand the formation and use of ADL scores? 2. How are ADL scores reported to the team and utilized during Medicare coverage discussions? 3. What specific impact do ADL scores have on payment levels in the RUG IV payment system? 4. Do any members of your team clinical or financial document ADL scores on RUG distribution reports? 1. This is essential documentation! WHAT IT MEANS FOR YOU Is ADL documentation training included in all front line staff orientation with competency testing? Do front line staff use electronic point of care documentation systems correctly? You should hear the stories! Since ADL scores drive payment up to $100 per day could your ADL codes on the MDS withstand audit? Reproducible documentation is REQUIRED by the regulation Are any ADL performance scores or support coded from staff interviews? Big Problem! 11
12 STEPS TO YOUR SOLUTION Identify the problem Front line documentation must be accurate during the ARP 24/7 Accountability is necessary You need to know the quality of your coding first and then focus on correcting the errors and incomplete documentation. STEPS TO YOUR SOLUTION Key members of the data collection, processing and billing team must have a complete understanding of the processes, rules and definitions. Who Reads and Understands the RAI Manual? Communication within this team is essential as well as regular contact for problem solving. Software must be integrated so data is moved seamlessly between the data collection, MDS Data Set, transmission and billing processes. BE CAREFUL WITH MINUTES! The minutes of therapy that are documented on the MDS are attested to for accuracy according to the rules in the RAI manual. Does this correspond with therapy staffing levels? People who code minutes of skilled therapy need to code the type of minutes delivered with each treatment. Be VERY Careful! Total minutes of delivery are not necessarily billable to the RUG. Operational Leadership needs to visit and observe the therapy department 12
13 RESOURCES FOR OPERATIONS RAI manual Chapter 3 Section O Pages 14 to 24. Skilled therapy definition and coding minutes of therapy directions. RAI Manual Chapter 6 Payment System pages September 2010 update calculation of billable minutes from total minutes. Example in the manual can be entered into therapy software to check that calculations are correct. RESOURCES FOR OPERATIONS Have therapy show you how the minutes are documented in their records which go into the medical records and then how the minutes are collected for the MDS and tracked for payment levels These are three separate tasks which have all been adapted or changed in the new process. Problems include the reduction of concurrent and possibly group minutes. THERAPY SIGNS THE MDS ATTESTATION FOR THERAPY MINUTES. Monitoring is essential IT IS YOUR RISK! WHAT HAPPENS IF WE GET THIS WRONG? Validation may be difficult or not possible, and without validation, the MDS is not complete. Unexpected delays or reduction in payment or default rates none of which is advisable The facility assessment process can be out of compliance impacting payment and producing citations or audits. New Survey and Cert letter telling surveyors how to monitor compliance no forgiveness here even though CMS was not processing. The data base for the facility can be wrong impacting PAYMENT AND COMPLIANCE. THAT MEANS AUDITS AND SURVEY ACTIVITY. 13
14 STEPS TO TAKE 1. The MDS process is operational, change the structure if necessary and manage it carefully 2. Look at the assessment activity the numbers, the time lines for validation and the efficiency of the process. 3. Is the data base accurate if not why not? 4. Inaccurate data reduces payment. 5. Review RUG distribution with ADL scores KEY POINTS TO REMEMBER Look at the MDS office for efficiency, and work space quality. Monitor wasted time in the data entry process What resources does the MDS manager need to complete the assessments? Meet with the MDS Manager weekly to discuss assessment activity, documentation issues and data flow. Identify the communication between the MDS office and billing as well as the software performance in these areas. Check the compliance of the billing process Map out the data transfer process for late month Part A admissions. CLINICAL MANAGERS HAVE A SIGNIFICANT RESPONSIBILITY IN THE PROPER IMPLEMENTATION OF THIS INTERDISCIPLINARY FUNCTIONAL ASSESSMENT TOOL AND THE REVIEW OF THE DATA BASE IT CREATES. What data do you need reported? 14
15 REMEMBER The survey and payment teams have all the data and very sophisticated software to pull out specifics that relate to their process. What data are you monitoring like falls with injury except major, wandering, refusal of care, significant behavior outcomes, ADL score changes, shift or changes in BIMS and MSS scores How does the data set represent the facility and its services as well as the outcomes for its elders? Very important question. THANK YOU! 15
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