The CHARTS GROUP 2017 MDS, CMS & REGULATORY UPDATES NELIA ADACI RN, BSN CDONA, C-NE, RAC-CT VICE PRESIDENT QUOTES ABOUT CHANGE “The first step toward change is awareness. The second step is acceptance . - Nathaniel Branden “Your success in life isn't based on your ability to simply change. It is based on your ability to change faster than your competition, customers, and business” . - Mark Sanborn “Resistance at all cost is the most senseless act there is”. - Friedrich Durrenmatt o “Change before you have to” . - Jack Welch KEY POINTS: KEEPING THINGS IN PERSPECTIVE I. Do not get overwhelmed. What is coming is better than what is gone. Let this belief aim you in the direction you need to go. – Karen Salmansohn II. Choice to be POSITIVE OR NEGATIVE If you don’t like change, you will like irrelevance even less. – Gen. E. Shinseki In order to carry a positive action, we must develop here a positive vision. – Dalai Lama III. Look at the “Big Picture” Nothing is coincidence in strategical perception IV. Focus on “INTENT”, instead of just Paper Compliance Always ask: “Why do we need to do this? What outcome do we want in doing this?” Page 1 of 90 1
LEARNING OBJECTIVES 1. Obtain a working knowledge and understanding of the recent updates in SNF Regulatory Changes and Medicare Updates 2. Learn the 2017 Updates in MDS 3.0 RAI Manual Version 1.15 3. Get familiar with the New Requirements of Participation, specifically the New Survey Process 4. Understand the importance and significant impact of accurate MDS and UB-04 Coding in ensuring a facility’s fiscal survival AGENDA MDS 3.0 RAI USER’S MANUAL VERSION 1.15 NEW REQUIREMENTS OF PARTICIPATION Overview of Regulation Reform & 3 Phases of Implementation Phase 2: F-Tag Renumbering; New Interpretive Guidance (Appendix PP); Comparison between Old versus New LONG-TERM CARE SURVEY PROCESS: A Practical Approach AGENDA (CONTINUATION) MEDICARE/CMS UPDATES & CLINICAL REIMBURSEMENT CHALLENGES Claims and Appeals Updates A Notation on Managed Medicare Audits Revision of CMP’s Quality Measures (Data and Outcomes): The New Currency Page 2 of 90 2
2017 MDS 3.0 UPDATES VERSION 1.15 MDS 3.0 CHANGES & UPDATES EFFECTIVE OCTOBER 1, 2017 New MDS 3.0 Items: Sections N & P New Coding Guidance, Revisions, or Clarifications to MDS Sections and Items Review NPE Requirements SECTION N: MEDICATIONS CMS added “OPIOIDS” as a classification in N0410 CMS added MDS questions pertaining to an “Antipsychotic Medication Review” Page 3 of 90 3
SECTION N: OPIOIDS Prevalence of Long-T erm Opioid Use in Long-Stay Nursing Home Residents: First published: 21 September 2017 Jacob N Hunnicutt, Stavroula A Chrysanthopoulou, Christine M Ulbricht, Anne L Hume, Jennifer Tjia and Kate L Lapane One in seven NH residents was prescribed opioids long-term. Recent guidelines on opioid prescribing for pain recommend reducing long-term opioid use, but this is challenging in NHs because residents may not benefit from nonpharmacological and nonopioid interventions. Studies to address concerns about opioid safety and effectiveness (e.g., on pain and functional status) in NHs are needed. SECTION N: OPIOIDS SECTION N: OPIOIDS N0410H, Opioid: Record the number of days an opioid medication was received by the resident at any time during the 7-day look-back period (or since admission/entry or reentry if less than 7 days). Same coding rules as other listed medication types Applies to all item sets except: NO, NPE, NS/SS, NY/SS Page 4 of 90 4
MOST COMMON OPIOIDS Codeine Fentanyl (Actiq, Duragesic, Fentora) Hydrocodone (Hysingla ER, Zohydro ER) Hydrocodone/Acetaminophen (Lorcet, Lortab, Norco, Vicodin) Hydromorphone (Dilaudid, Exalgo) Meperidine (Demerol) Methadone (Dolophine, Methadose) Morphine (Astrammorph, Avinza, Kadian, MS Contin, Ora-Morph SR) Oxycodone (Oxycontin, Oxecta, Roxicodone) Oxycodone and Acetaminophen (Percocet, Endocet, Roxicet) Oxycodone and Naloxone (Targiniq ER) SECTION N: ANTIPSYCHOTIC MED REVIEW SECTION N: ANTIPSYCHOTIC MED REVIEW CMS added MDS questions pertaining to an Antipsychotic Medication Review Consists of 5 questions Applies to Comprehensive (NC) and Quarterly (NQ) item sets only Page 5 of 90 5
SECTION N: ANTIPSYCHOTIC MED REVIEW NO45OA: Did the resident receive antipsychotic medications since admission/entry or reentry or the prior OBRA assessment, whichever is more recent? • Code 0, no: if antipsychotics were not received: Skip to O0100, Special Treatments, Procedures, and Programs. • Code 1, yes: if antipsychotics were received on a routine basis only: Continue to N0450B, Has a GDR been attempted? • Code 2, yes: if antipsychotics were received on a PRN basis only: Continue to N0450B, Has a GDR been attempted? • Code 3, yes: if antipsychotics were received on a routine and PRN basis : Continue to N0450B, Has a GDR been attempted? SECTION N: ANTIPSYCHOTIC MED REVIEW NO45OB: Has a Gradual Dose Reduction been attempted? • Code 0, no: if a GDR has not been attempted. Skip to N0450D, Physician documented GDR as clinically contraindicated. • Code 1, yes: if a GDR has been attempted. Continue to N0450C, Date of last attempted GDR. SECTION N: ANTIPSYCHOTIC MED REVIEW NO45OC: Date of Attempted GDR Enter the date of the last attempted Gradual Dose Reduction. Page 6 of 90 6
SECTION N: ANTIPSYCHOTIC MED REVIEW NO45OD: Physician documented GDR as clinically contraindicated Code 0, no: if a GDR has not been documented by a physician as clinically contraindicated. Skip to O0100, Special Treatments, Procedures, and Programs. Code 1, yes: if a GDR has been documented by a physician as clinically contraindicated. Continue to N0450E, Date physician documented GDR as clinically contraindicated. SECTION N: ANTIPSYCHOTIC MED REVIEW NO45OE: Date Physician documented GDR as clinically contraindicated Enter date the physician documented GDR attempts as clinically contraindicated. SECTION N: ANTIPSYCHOTIC MED REVIEW Coding Tips and Special Populations Any medication that has a pharmacological classification or therapeutic category as an antipsychotic medication must be recorded in this section, regardless of why the medication is being used. In this section, the term physician also includes physician assistant, nurse practitioner, or clinical nurse specialist. Do not include Gradual Dose Reductions that occurred prior to admission to the facility (e.g., GDRs attempted during the resident’s acute care stay prior to admission to the facility). Page 7 of 90 7
SECTION N: ANTIPSYCHOTIC MED REVIEW Coding Tips and Special Populations Physician documentation indicating dose reduction attempts are clinically contraindicated must include the clinical rationale for why an attempted dose reduction is inadvisable. This decision should be based on the fact that tapering of the medication would not achieve the desired therapeutic effects and the current dose is necessary to maintain or improve the resident’s function, well-being, safety, and quality of life. SECTION N: ANTIPSYCHOTIC MED REVIEW Coding Tips and Special Populations Within the first year in which a resident is admitted on an antipsychotic medication or after the facility has initiated an antipsychotic medication, the facility must attempt a GDR in two separate quarters (with at least one month between the attempts), unless physician documentation is present in the medical record indicating a GDR is clinically contraindicated. After the first year, a GDR must be attempted at least annually , unless clinically contraindicated. SECTION N: ANTIPSYCHOTIC MED REVIEW Coding Tips and Special Populations Do not count an antipsychotic medication taper performed for the purpose of switching the resident from one antipsychotic medication to another as a GDR in this section. In cases where a resident is or was receiving multiple antipsychotic medications on a routine basis, and one medication was reduced or discontinued, record the date of the reduction attempt or discontinuation in N0450C, Date of last attempted GDR. If multiple dose reductions have been attempted since admission/entry or reentry or the prior OBRA assessment, record the date of the most recent reduction attempt in N0450C, Date of last attempted GDR. Page 8 of 90 8
SECTION P: RESTRAINTS AND ALARMS CMS incorporated the capture of Alarm Use in Section P Section Title was changed to Restraints and Alarms Addition of Alarms has no impact on Restraint QM -YET SECTION P: RESTRAINTS & ALARMS SECTION P: RESTRAINTS & ALARMS Page 9 of 90 9
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