Several facilities have reported to SimpleLTC that, in certain circumstances, a submitted and accepted discharge assessment is not being reflected on the MDS 3.0 Roster report and other CASPER reports.
As part of CMS S&C letter 13-56, CMS reminded all nursing facilities (NFs) that discharge assessments are required assessments under 42 CFR §483.20(g) and 42 CFR §483.20(f)(1) and must be completed according to assessment scheduling guidelines in the RAI Manual.
As part of the letter, CMS directed all NFs to review their MDS 3.0 Roster report from CASPER to identify residents with missing discharge assessments. Simply put, the MDS 3.0 Roster report lists all residents for whom the latest accepted, federally required assessment is not a Discharge assessment (A0310F = 10, 11, or 12). Once a discharge assessment has been submitted and processed for the resident, the resident will no longer appear on the MDS 3.0 Roster report unless a new assessment is submitted with a later target date.
After researching the issue, it appears there are two common causes for this issue:
1) Incorrect Coding of A0410
All discharge assessments must be coded with A0410 (Submission Requirement) = 3 (Federal required submission) in order to fulfill regulatory discharge reporting requirements for residents who are in a Medicare / Medicaid certified unit. If A0410 = 2, the discharge assessment will be unavailable to Federal authorities since they do not have legal authority to view the assessment data and it will be as if the facility did not submit a discharge assessment.
If a facility miscodes A0410, they will need to contact their state RAI coordinator in order to submit an MDS 3.0 Manual Assessment Correction/Deletion Request per the guidelines in the RAI Manual Chapter 5. Coding errors involving A0410 cannot be corrected with a normal modification or inactivation assessment.
2) Resident information doesn't match previous assessments
In order for the discharge assessment to be properly reflected, the resident ID on the 'Final Validation' report must match the resident ID shown on the MDS 3.0 roster report. MDS 3.0 will create a new resident ID if the Section A demographics do not exactly match what is already in the system and the discharge assessment will be applied to that new resident ID. If this happens, identify the information that was incorrectly entered and do a modification request to correct it. Once the modification is accepted, the assessment should appear under the correct resident ID and disappear from the MDS 3.0 roster report.
A0410 (Submission Requirement)
A0410 determines which governmental authorities have access to see or use MDS data.
If A0410 = 3, MDS data can be used by both CMS and state authorities.
If A0410 = 2, MDS data cannot be used by CMS and is only shared with state authorities.
If A0410 = 1, the QIES ASAP system will always reject the assessment.
If facilities code discharge assessments with A0410 = 2 (State but not federal required submission), the Federal government cannot use the assessment for discharge reporting purposes since the code is telling them that they are not allowed to see or use the assessment data for Federal purposes.
The RAI Manual (as of the date of this article) provides the following guidance when coding A0410:
Code 1, neither federal nor state required submission: if the MDS record is for a resident on a unit that is neither Medicare nor Medicaid certified, and the state does not have authority to collect MDS information for residents on this unit. If the record is submitted, it will be rejected and all information from that record will be purged.
Code 2, State but not federal required submission: if the MDS record is for a resident on a unit that is neither Medicare nor Medicaid certified, but the state has authority, under state licensure or other requirements, to collect MDS information for these residents.
Code 3, Federal required submission: if the MDS record is for a resident on a Medicare and/or Medicaid certified unit.
When a resident is in a Medicare and/or Medicaid certified unit, the MDS assessment should be coded with A0410 = 3 regardless of payer.
Please note: In all situations, nursing facilities should defer to the guidance of the RAI Manual and their state RAI coordinators. If you have any questions, please do not hesitate to contact SimpleLTC Support.
CMS Resident Match
When an assessment record is accepted into the QIES National database, the system compares the resident-identifying information contained in the assessment record to the existing resident records in the Resident table. Based upon specific criteria listed below, this process determines if the resident is a new resident or one for whom a resident record already exists. If the resident-identifying information submitted in the assessment record is sufficiently similar to the resident information in an existing resident record, a match occurs and the assessment is associated with the existing resident record. If the resident-identifying information in the assessment record is not sufficiently similar to an existing resident record, a new resident record is created in the Resident table and the assessment record is associated with that new resident record.
For reference, CMS has posted details of the Resident Matching process in Appendix B of the MDS 3.0 Provider User's Guide.