Providers worried about CMS pace on new MDS materials

Skilled nursing operators were happily surprised in September with an early draft of MDS revisions, but ever since it’s been a slog getting more information. 

Thursday only heightened frustrations as regulators projected that an interpretive manual and training sessions could still be as long as five months or more away, leaving providers just a few months before an Oct. 1, 2023, implementation date.

Centers for Medicare & Medicaid Services leaders originally indicated that new MDS v1.18.11 data sets would be delivered by the end of this year. That window is closing rapidly. In addition, on Thursday, agency officials told listeners on the agency’s SNF/LTC Open Door Form conference call that the RAI interpretive manual will “probably” be ready in the second quarter of 2023 and training sessions will “probably” be in mid-May, and workshops in June.

Skilled nursing providers were advised to take their cues from CMS guidance for other care sectors.

“They seem to think that we can use trainings that have been posted for home health, IRF and LTCH settings related to the standard items that are found on those tools as well,” rued Joel VanEaton, executive vice president of PAC Regulatory Affairs and Education with Broad River Rehab, in a follow-up interview with McKnight’s Long-Term Care News. 

It was Van Eaton’s question during the forum’s call that set off the disappointing answers from regulators.

“Unfortunately, notwithstanding the fact that these were developed for other settings,” he said, “it appears that those are not specifically related to the items we will be most concerned with, namely the new items like the SPADEs (Standardized Patient Assessment Data Elements), TOH (transfer of health information) items and significant revisions to section N and O etc.”

Pregnant pauses during the Q&A part of the call were particularly telling, VanEaton and others felt.

“It was noteworthy that they seemingly have no thought on how we will have to adjust to the effect that the elimination of section G items will have on the QMs, CAAs, staffing acuity and so forth, as they did not know if the trainings that are forthcoming address this issue,” VanEaton noted.

The pace of information reveal is especially bothersome because providers are expecting residual effects in numerous areas affected by the MDS, such as Care Area Assessments, quality measures and Five-Star ratings. 

Others, including software developers, will need to devise new processes based on the MDS specifications that aren’t yet finalized, noted expert Leah Klusch at the time of the draft release. The executive director of the Alliance Training Center, Klusch noted that it also was not known how the payment process will be affected by changed MDS items.

“The industry will not be completely up to speed by Oct. 1 with this timeline,” said VanEaton. “CMS had these changes completed two years ago (but were held back due to the pandemic). My question is why is it taking so long to get us resources? As of today, Dec. 8, all we have so far is the draft comprehensive data set. We have a lot to learn beyond just the data set changes.”

Another caller asked whether the new MDS format would include any changes in hearing or vision assessments since “they are currently subjective assessments, which is not a valid, objective way of assessing” and discussions with CMS about them had begun in 2017.

“When somebody has a hearing problem, it could be seen as a mental or cognitive disorder,” the physician said. “Unfortunately, speech professionals are not screening hearing before doing an evaluation. Ninety percent of people in facilities have a hearing problem.”

There are no changes in this area of the new version, an agency spokeswoman said.

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