Coming October 1, 2018, there are changes to the MDS that will include a number of additions to section GG. The changes were published in December by CMS. As you may know, Section GG is a response to the IMPACT Act and not collecting enough data could negatively impact your annual percentage update by as much as 2% of your reimbursement. The scoring of these items impacts your quality measures and 5-star rating as well. These changes will mean that increased communication and collaboration will be necessary between nursing and therapy.
The changes to Section GG focus on two primary things: 1) capturing resident’s function prior to admission and 2) some new coding level items being added to the self-care and mobility sections.
We found the American Association of Nurse Assessment Coordination to offer the most helpful summary of the new coding levels and coding sets.
Mark McDavid, OTR, RAC-CT notes in his summary that “all of the new items are function focused, and most are well suited to being captured by your therapy team. That doesn’t mean that section GG should be done by only your therapy team. If you think back to when section GG was first implemented, CMS indicated that the coded level captured should be the 'usual performance' prior to any treatment intervention. While it is easy to allow therapy or nursing alone to capture the section GG items, we would caution against this. Therapists are highly skilled in capturing such data, but residents often behave differently in therapy than they do on the floor or in their room. Simply allowing your therapy provider to capture the section GG data and entering their scores on the MDS without nursing input does not show the full picture of the resident and may not be the ‘usual performance’.”
In summary, we recommend that providers develop a collaborative process between therapy and nursing services to best determine “usual performance.” That collaboration should include nursing interviews, as well as direct observation, and it should be across all three shifts because what a resident does on the day shift may not be reflected on the evening shift. Teams will also need to determine who will collect the data about resident function prior to admission.
Teamwork between therapy and nursing has become essential in this quality based environment and establishing good communication systems now will help with the upcoming changes in the MDS. Accurate coding will also demonstrate the true quality outcomes your facility is achieving on nursing home compare.