PPS Assessment: Modifying Assessment After Transmission

Providers have long struggled with items that may not be modified on the MDS 3.0 assessment.  Occasionally, a typographical or data entry error will cause an assessment to be submitted with the Reason for Assessment (RFA) coded incorrectly in one of the many fields in Section A0310A-G.  Providers only option was to inactivate the assessment with the error and complete a new assessment when the error was discovered with the current date as the ARD.  If the resident was no longer covered under Medicare Part A when the error was discovered the facility would be unable to replace the inactivated assessment.  

Beginning on May 19, 2013, providers will have the option to modify this item on the MDS when the facility identifies an error in the RFA.  Providers will be able to modify the assessment to correct an error in this field, provided the assessment item set does not change.  The ability to modify the RFA on an assessment that is otherwise valid eliminates financial penalties that resulted under the previous policy, which required the assessment to be inactivated resulting in a late or missed assessment.  Modifying the assessment would enable the facility to appropriately bill the HIPPS code generated for the number of day covered by the assessment type. 

There are ten possible item sets that could be completed and the coding of the reason for assessment determines which item set is selected for completion.  

For example, the comprehensive item set (NC) is a full item set that includes the CAA process.  Scheduled Medicare assessments are completed using the PPS (NP) item set.  When a scheduled Medicare assessment is dually coded as an OMRA assessment in section A310C, the PPS item set would be used.  In situations where the facility completes an unscheduled OMRA assessment, the item set selected could differ depending on the type of OMRA completed.  Specifically, the End of Therapy (EOT) OMRA and Change of therapy (COT) OMRA are both completed using the same EOT OMRA (NO) item set.  When an unscheduled Start of Therapy (SOT) OMRA is completed, the SOT (NS) item set used is significantly shorter.  Since the only objective of this assessment is to calculate a rehabilitation RUG category, the item that would be required to calculate a non-therapy RUG category are not included in this item set.

Listed below are some examples of situations in which a modification in the reason for assessment field will be allowed due to the item set not changing from this modification subsequent to acceptance in the QIES database:

• The RFA could be appropriately modified when an assessment was completed and submitted to the QIES ASAP database with an ARD of day 27 and was intended to be the scheduled 30 day Medicare MDS. This assessment was incorrectly coded as a 14 day Medicare assessment.  In this case, the PPS item set is completed for both types of assessments and modification of the RFA would be the appropriate corrective action.
• Similarly, if the facility correctly completed an assessment three days after the last therapy treatment session and incorrectly coded the RFA as a COT instead an EOT, the OMRA (NO) item set is completed for both assessment types and the reason for assessment could be modified.
• If the facility completed a discharge assessment that is also coded as a 5 day Medicare Assessment then the PPS item set is completed.  This assessment should have also been coded as a SOT OMRA, but the omission was not discovered until after transmission.  The item set will not be altered by modifying section A0310C to indicate the assessment is also a SOT OMRA.  As a result completing a modification to correct the coding of this assessment is an acceptable course of action.