RAI Newsletter
Contents
1. RAI Spotlight Surveyor Access to EHRs In early February a reminder was posted on the Department of Health message board to facilities that use Electronic Health Records EHR Pro viders must allow access to any medical record including access to EHRs when requested by the surveyor It is the fa cility s responsibility to provide direc tion on the use of the electronic system or to designate an individual to access the system in response to questions or to assist the survey team A delay in the acquisition of the medical record is unacceptable and may delay the survey process Delaying the access or imped ing the survey process would warrant contact by the State Agency to CMS which may lead to termination from Medicare participation To facilitate the survey process if your facility utilizes EHRs a good first step is to be proactive Keep in mind that Department of Health surveys are unan nounced so be sure to have a plan ready Being prepared will enable you to meet the Department s expectation of access to EHRs within two hours of the survey team s arrival Here are some other helpful tips e Make sure that the user names and passwords assigned to surveyors work properly e Provide instructions for navigating your system and designate a staff mem ber to be a resource for surveyors if they require assistance accessing EHRs e Assure that surveyors are able to ac cess EHRs on devices in2. RAI Manual page 2 55 The emphasis in this instruction is to convey that two separate assessments cannot be performed in the ARD window e g a 14 day assessment on Day 13 and a COT on Day 15 or vice versa If both must be completed they must be combined with the ARD on Day 7 of the COT observation period Additional instruction is provided on page 2 51 If Day 7 of the COT observation period falls within the ARD win dow of a scheduled PPS Assessment the SNF may choose to complete the PPS Assessment alone by setting the ARD of the scheduled PPS assessment for an allowable date that is on or prior to Day 7 of the COT observation period This Quality Care in Nursing Facilities Everyone wants quality care to be provided in the nursing facility In an effort to identify quality care and ensure its provision many organizations and programs have been developed often leading to confusion CMS has re leased a document outlining several of the programs and responding to Frequently Asked Questions Q In regards to Functional Limitation in Range of Motion coding Ifa resident has a cast are we to assume that they are always considered to have an impairment on one side and be coded as a due to immobility or can we more spe cifically look at the fact that the resident who is unable to move due to being in a cast yet is casted in a functional ROM of neutral which is not impeding her ability to mobi lize or perform tasks be considered a
3. e Be prepared to print documents and records from your system when the surveyors request hard copies e If your facility uses both paper records and EHRs com municate to the survey team what records are maintained in each format Quick Tips www dpw state pa us publications forproviders QuickTips P_039560 and ICD 10 FAQs www dpw state pa us provider icd10information icd10faqs indes htm October will be here shortly Be certain your facility is ready to smoothly transition to the new coding system The reference number for the CMS Survey and Certification Memo regarding the subject of surveying facilities that use electronic health records EHR is S amp C 09 53 and can be downloaded from the CMS website http www cms gov Medicare Provider Enrollment and Certification SurveyC ertificationGenInfo Policy and Memos to States and Regions html
4. 0 as it is not impairing their mobility or self care In most cases a resident in a cast has a functional limitation due to a non weight bearing status altered weight bearing status and not due to the im mobility of a limb A joint casted in neutral although im mobile does not impede a resident s ability to mobilize or perform ADLs in some case it may even assist The de creased ability to perform mobility or ADLs is due to the resident s inability to maintain non weight bearing status in attempts to transfer or stand to put pants on for example and not due to the fact that their ankle is immobile A As stated in the coding instructions Do not look at limited ROM in isolation You must determine if the limited ROM impacts functional ability or places the resident at risk for injury The coding of this item will be resi dent specific dependent on the impact to that resi dent effectively resets the COT observation period to the 7 days following that scheduled PPS Assessment ARD Alter nately the SNF may choose to combine the COT OMRA and scheduled assessment following the instructions dis cussed in Section 2 10 The SNF has the option to per form only the scheduled PPS assessment e g if Rehabilita tion group is now at a lower level or to combine the sched uled PPS assessment with a COT if the Rehabilitation group will be at a higher level and the SNF wants to capture the higher rate for the previous 7 days The S
5. NF must evaluate each individual situation to identify which pattern of assess ment completion will be of benefit to the facility and still follow RAI Manual instructions Another bullet on page 2 51 states The COT ARD may not precede the ARD of the first scheduled or unscheduled PPS assessment of the Medicare stay used to establish the patient s current RUG IV therapy classification A COT cannot be used as the first assessment to establish a Reha bilitation RUG Ifthe COT results in a Nursing RUG rather than a Rehabilitation RUG only the next scheduled PPS assessment can restart the Rehabilitation RUG if therapy has increased CMS is evaluating this situation www cms gov Medicare Provider Enrollment and Certification QAPI Downloads Aligning QAPI FAQ pdf Guidance is provided about the various programs their implementation and integration Volume 8 Issue 3 Be Careful of These Numbers CMS has been tightening MDS edit requirements in order to ensure greater data accuracy particularly in facility identifi ers What are these numbers e FAC ID This is the number assigned by the state agency to the nursing home and reported in the Control Sec tion of the MDS file For most facilities in PA this number starts with PA It is automatically filled in by your soft ware so if there are issues you may need to contact your vendor e A0100A Facility National Provider Identifier NPI The NPI is a uniqu
6. e 10 digit identification number issued to health care providers in the United States by CMS e A0100B Facility CMS Certification Number CCN This is often referred to as the Medicare number It must be Preparing for ICD 10 CM Beginning on October 1 2014 every entity covered by the Health Insurance Portability and Accountability Act HIPAA must use the International Classification of Dis eases 10 edition ICD 10 CM rather than ICD 9 codes There is no grace period forms or transactions with a date on or after October 1 2014 must use ICD 10 codes or be rejected Forms or transactions with a date on or before September 30 2014 must use ICD 9 codes This affects both Medicare and Medicaid programs CMS has developed many materials to aid in the transition www cms gov Medicare Coding ICD10 2014 ICD 10 CM and GEMs html A Frequently Asked Questions document on ICD 10 Transition Basics www cms gov Page 3 six digits letters long In Pennsylvania it often starts with 39 e A0100C State Provider Number This is often referred to as the Medicaid number This is the 13 digit MA number that is used in the PROMISe system If your facility does not participate in the MA program this item may be left blank CMS is comparing these numbers on submitted assessments to assure that they all belong to the same provider and to be certain they match the numbers in the CMS database It is very important that thes
7. e numbers be correct so the residents and assessments are properly assigned to your facility par ticularly if there has been a Change of Ownership CHOW If you have been receiving an error on your Final Validation Report related to these numbers contact the Myers and Stauffer Help Desk for assistance 717 541 5809 publications bulletinsearch bulletinselected index htm bn 99 14 03 Claims received on or after July 1 2014 using previous versions of the form will be returned to the provider All Pennsylvania Medical Assistance enrolled individual providers provider groups clearing houses software ven dors billing services and managed care organizations must convert to ICD 10 on October 1 2014 The Department will make all necessary changes in PROMISe to support the ICD 10 requirements A dedicated web page has been added to the Department s provider information website at www dpw state pa us provider icd10informations P_012571 Documents of special interest are the Provider Medicare Coding ICD 10 Downloads ICD10FAQs2013 pdf is a good introduction Evaluate where ICD 9 codes are used in your facility such as MDS completion and the bill ing department and begin to plan for the transition In another necessary change to support ICD 10 NFs must begin using CMS 1500 Health Insurance Claim Form version 02 12 on July 1 2014 www dpw state pa us Surveyor Access to EHRs cont d Continued from page 1
8. eceived during the teleconference but the following questions were received through the DOH mailbox Q Can you provide some examples of obstructive uropa thy A Obstructive uropathy occurs when urine cannot drain through a ureter urethra potentially flowing back up into the kidney causing hydronephrosis Common causes of ob structive uropathy include bladder stones kidney stones benign prostatic hyperplasia and bladder or ureteral can cer As with all diagnoses in order to code obstructive uro pathy MDS Item 11650 on the MDS all of the criteria stated in the RAI User s Manual for coding an active diag nosis must be met Q In coding G0600 is the only acceptable chair a wheel chair A Yes CMS has clarified in the past that Geri Chairs Broda chairs and other chairs with wheels are not to be coded as wheelchairs on the MDS in item G0600 COT Questions Judging by calls received there is continuing confusion as to when COT and PPS assessments should be combined Guidance in the RAI Manual is somewhat conflicting If Day 7 of the COT observation period falls within the ARD window including grace days of a scheduled PPS Assess ment and the ARD of the scheduled PPS assessment has not been set for a day that is prior to Day 7 of the COT ob servation period and a COT OMRA is deemed necessary upon completion of the change of therapy evaluation than the SNF must combine the COT OMRA and the scheduled assessment
9. resident care areas as well as other areas such as con ference rooms e Survey teams may include four or more staff members so make sure there is adequate equipment available Continued on page 3 Section J Health Conditions Teleconference 1 30 2 30 pm EDT Dial in 10 minutes earlier Date April 17 2014 Time Topic Section J Health Conditions Handouts Power Point slides will be available about April 14 on the DOH Message Board at http app2 health state pa us commonpoc content facilityweb login asp Callin number 1 888 694 4728 or 1 973 582 2745 Conference ID Number 88715377 Company Name Myers and Stauffer Moderator Cathy Petko A recording of this conference will be available directions for requesting this will be posted on the DOH Message Board Additional questions ga mds pa gov pennsylvania DEPARTMENT OF HEALTH j RAI Coordinator 1 717 787 1816 qa mds pa gov Volume 8 Issue 3 February 2014 Questions about the RAI Please submit them to qa mds pa gov Inside this issue Section H Bowel and 2 Bladder Q amp As COT Questions 2 Quality Care in 2 Nursing Facilities Be Careful of These 3 Numbers Preparing for 8 ICD 10 CM Volume 8 Issue 3 Section H Bowel and Bladder Q amp As On January 16 2014 a training teleconference was pro vided on Section G Functional Status Items G0120 through G0900 and Section H Bowel and Bladder No questions were r
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