The Problem

CMS has discovered a potential issue that can cause problems and result in missed assessments and other possible consequences for providers.

In some circumstances, providers have reported that assessments submitted by one provider have shown up on CASPER reports belonging to an entirely different facility. In all scenarios, the MDS batch is uploaded either by a user with access to multiple facilities.

This issue is serious because it can result in missed assessments, delayed reimbursement, and possibly violations of the HIPAA privacy rule.

The Cause: Incorrect facility ID on the MDS

Each valid MDS 3.0 assessment must contain both a state-assigned facility ID (FAC_ID) and state code (STATE_CD) in order to be accepted by the QIES ASAP system. The combination of these two values uniquely identifies the facility and is used to associate MDS assessments with the proper facility in the CMS national database.

SimpleLTC has linked this issue to the common practice of duplicating clinical software configurations when a new facility is opened or when a facility’s clinical software is upgraded or replaced. Like most software packages, the initial setup of clinical software often involves a lot of customization and configuration to meet each company’s specific needs. Often many of these decisions are made at the corporate level and apply to all facilities in a chain. As a result, when a new facility is opened or clinical software is replaced, it is common for the configuration of a known existing facility with the same ownership (the source facility) to be duplicated and used as a template for the clinical software installation at the new facility.

Part of the clinical software configuration is the state-assigned facility ID that is included on each MDS assessment. If the provider does not take care to ensure that the clinical software configuration at the new facility is changed to reflect the new facility’s facility ID then newly created assessments will be coded with the incorrect facility ID and any submitted assessments will be erroneously linked to the source facility instead of the new facility.

The Solution

When a new facility is opened or clinical software is updated or replaced, providers must take care to ensure that the state-assigned facility ID (FAC_ID) is set to the correct value for the facility before beginning to transmit MDS assessments. Providers can contact their clinical software vendor for instructions on how to set the state-assigned facility ID value in their clinical software system. If an incorrect facility ID value is suspected or has been identified, providers should immediately cease transmitting MDS assessments until the issue is resolved to avoid possible HIPAA violations.

Providers who do not know their state-assigned facility ID should contact their State RAI Coordinators so that a facility ID can be assigned.

Providers who have already submitted assessments to CMS with an incorrect FAC_ID value must follow the manual correction request as outlined in Chapter 5 of the RAI Manual in order to have the assessments removed from the Federal database. To begin the process, facilities should contact their State RAI Coordinators.

If you have any additional questions, please do not hesitate to contact the SimpleLTC Support Team.