MDS 3.0 updates require critical action steps

With the federal government’s escalating war on healthcare fraud and abuse, long-term care operators are on high alert in their efforts to be compliant in documentation and reporting. To that end, the Zone Program Integrity Contractors (ZPICs), established by the Centers for Medicare & Medicaid Services are different from other CMS contractors in that they don’t conduct random audits, they can make unlimited document requests and they don’t offer specification for look-back periods.

In light of the ramped up regulatory landscape, LTC educator and trainer Leah Klusch is busier than ever in her mission to prepare operators to meet the increasingly complex requirements for skilled nursing facilities to remain compliant while achieving fair reimbursement. Last week she addressed a user group conference in Cleveland organized by eHealth Data Solutions.

“We work in numbers and codes. If you think they [surveyors] are out there to support us … well, they’re there to cut payment, make us accountable and impair some of our mission,” declared Klusch.

To fight this battle, as she refers to it, Klusch pounds home the need for documentation and compliance. She urges operators to stay on top of recent revisions to the Medicare benefit policy manual and to educate staff. “Get the proper change documents,” Klusch said. “This is a lot about details—important details. Check all areas of the manual for errata information and follow up.”

Here are a few more specific guidelines from Klusch:

• Assess schedules, transmission policies, interviews and other data. Collection processes must match the RAI manual instructions.
• All team members must be involved and understand what the collected data says about the facility and its services.
• The section with the most changes is Q—be careful.
• Pay special attention to Section I—diagnosis/billing issues.
• Monitor the CMS website. Keep in touch with state and national associations. Refer to online resources like The Compliance Store.

Patricia Sheehan

Patricia Sheehan was Editor in Chief of I Advance Senior Care / Long Term Living from 2010-2013. She is now manager, communications at Nestlé USA.