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1. does not constitute direct legal or regulatory advice AANAC BOARD ANNOUNCES 2012 2013 SLATE LETTER oe Dear AANAC Members On behalf of the Board of Directors want to thank everyone who participated in our nominating process Our nominees represent the best and brightest in terms of knowledge skills and commitment to the issues that affect long term care Because the candidates were so well qualified selecting among them was a daunting task The Nominations Committee reviewed everyone who was nominated to identify those with the knowledge experience and skills to fill a Board position After this initial screening candidates were interviewed and evaluated according to the criteria established by the Board to strengthen the Board of Directors As a result of these deliberations the top nominees were recommended by the Nominations Committee to the Board of Directors for approval The Board of Directors is pleased to announce the following slate of candidates for your consideration Peter Arbuthnot rac ct Stephanie Kessler rac ct Carol Maher rn sc Rac cT Carol Smith rn Bsn Rac ct Regulatory Industry Analyst Principal Director of Education Supervisory Consultant American HealthTech Inc Reinsel Kuntz Lesher LLP Hansen Hunter amp Co P C BKD CPAs and Advisors Jackson Mississippi Lancaster Pennsylvania Vancouver Washington Tulsa Oklahoma Jo Anna Hurd rn msn Rac cT Linda Krueger Benjamin Ruggles Clinic
2. or scheduled toileting With the updated definition coders will focus on the voluntary and intended nature of the void in approved receptacles Appendix A p A 5 Traditional Survey Guidance continued from page 1 the list to the Phase 1 resident sample to ensure that a minimum of four residents who are receiving antipsychotic medications are in the sample Note CMS also instructs surveyors to consider residents receiving psychopharmacological medications specifically antipsychotic medications for possible selection in the Phase 2 resident sample Learn the difference between Phase 1 review and Phase 2 review on page 4 Surveyors have always done some drug reviews during survey notes Boyer However the process is now peppered with specific instructions involving aanac org 800 768 1880 antipsychotics For example ina comprehensive care review surveyors will review implementation of the resident s care plan the resident s response to the desired goals and interventions and the relationship of the resident s drug regimen to the resident s condition as well as the use of psychopharmacological medications specifically antipsychotic medications says 12 45 NH Similarly in a record review for either a comprehensive or focused review surveyors will review the latest comprehensive MDS paying particular attention to the resident s medication regimen including the use of psy
3. the completion of the Resident Assessment Instrument RAI including accurate coding and transmitting of the MDS and determine if the facility used the CAA process in developing an individualized care plan for the resident says 12 45 NH Similarly record reviews will be used to help validate or confirm whether the MDS assessments and care planning interventions accurately reflect the resident s status and identified needs and choices Phase 1 vs Phase 2 resident samples in traditional survey Phase 1 resident samples are preselected during Task 1 Offsite Survey Preparation based on quality measures and other areas of concern This pre selection is subject to amendment based on the information gathered during the tour entrance conference and facility Roster Sample Matrix This review focuses on care areas that were checked for the resident on the Resident Level QM Report and any additional items checked as pertinent to the resident e g all areas that are checked on the Roster Sample Matrix for the resident are reviewed whether or not they have been highlighted as concerns This includes all care areas the team has aanac org 800 768 1880 checked for the resident a review of the MDS the facility s use of the CAA Process care planning implementation and evaluation of the care plan and the resident s response to the care provided The dining observation is done for a resident if the
4. the wound A scab is made up of dried blood cells and serum sits on the top of the skin and forms over exposed wounds such as wounds with granulating surfaces like pressure ulcers lacerations evulsions etc A scab is evidence of wound healing more on page M 5 Reduce Unnecessary Medications While assuring that only those medications required to treat the resident s assessed condition are being used it is important to assess the need to reduce these medications wherever possible and ensure that the medication is the most effective for the resident s assessed condition p N 4 Isolation Definition Changed The concept of strict isolation has been amended to read single room isolation in multiple areas in section O Instructions in item Oo100M clarify that staff are to code this only when it includes isolation for active infectious disease and the resident requires transmission based precautions and single room isolation alone in a separate room because of active infection i e symptomatic and or have a positive test and are in the contagious stage with highly transmissible or epidemiologically significant pathogens that have been acquired by physical contact or airborne or droplet transmission p O 4 APPENDIX A Definition of Continence Changed Continence is any void into a commode urinal or bedpan that occurs voluntarily or as the result of prompted toileting assisted toileting
5. 7 and day 100 was 7 4 I just found out today If I am following you you want to use the RUG calculated from the Quarterly to make up for the missed assessment As long as the ARD of the Quarterly falls within the ARD window of the missed assessment you can do that See page 6 54 of the RAI User s Manual Rena R Shephard mua RN RAC MT c NE RRS2000 aol com AANAC LTC LEADER 11 15 2012 2012 AANAC No part of this publication may be reproduced without written permission from AANAC The information presented is informative and does not constitute direct legal or regulatory advice
6. AMERICAN ASSOCIATION OF NURSE ASSESSMENT COORDINATION LTC LEADER s a CMS Releases MDS 3 0 User s Manual Update The latest MDS 3 0 RAI User s Manual was posted on November 7 2012 and became effective immediately upon release MDSs with an ARD on or after this date are subject to the revised manual instructions The following is only a brief summary of the changes and we encourage you to read the extensive analysis of the update which is available through the MDS 3 0 Information and Resources page on AANAC org or through http bit ly 2012 Updates CHAPTER 1 Care Area Assessments Appendix C Tools Use Optional CMS has clarified that the CAA resources in Appendix C are provided as a courtesy to facilities The use of these resources are not mandatory and represent neither an all inclusive list nor government endorsement p 1 6 Resident Assessment Instrument Conceptualized The IDT is to work with the resident and or the resident s family guardian or other legally authorized representative and the resident s physician to determine the severity functional impact and scope of a resident s clinical issues and needs instead of their problems p 1 9 CHAPTER 2 Stand Alone Unscheduled Assessment Two Day Flexibility Period The two day flexibility period for opening and setting the assessment reference date ARD for stand alone unscheduled PPS assessments includes the Change of Therapy OMRA COT a sta
7. EADER 11 15 2012 2012 AANAC No part of this publication may be reproduced without written permission from AANAC The information presented is informative and does not constitute direct legal or regulatory advice MDS 3 0 User s Manual Update continued from page 2 window for that assessment and the resident has been discharged from Part A the assessment is missed and cannot be completed All days that would have been paid by the missed assessment had it been completed timely are considered provider liable However as with the late unscheduled assessment policy the provider liable period only lasts until the point when an intervening assessment controls the payment p 2 74 CHAPTER 3 Weight Loss and Weight Gain Look Back Window Changed Items Ko300 Weight Loss and Ko310 Weight Gain were both revised to read This item compares the resident s weight in the 7 day look back period with his or her weight at two snapshots in time To compare the weights find the resident s weight in the 7 day look back period and compare to a point closest to 30 days preceding the current weight and a point closest to 180 days preceding the current weight pp K 4 K 9 Unhealed Pressure Ulcers Item Mo210 Unhealed Pressure Ulcer s has a clarifying definition added Scabs and eschar are different both physically and chemically Eschar is a collection of dead tissue within the wound that is flush with the surface of
8. al Assessment Director RN AAS BA RAC CT BSN RN RAC CT C NE CPRA Miller s Health System Clinical Reimbursement Director Senior Director of Warsaw Indiana Community Eldercare Clinical Reimbursement Services Linden Tennessee Complete Health Resources Dresher Pennsylvania Following your review of the slate if no alternative candidates are put forth through a petition process these candidates will be approved and seated on July 1 2013 If you wish to nominate an alternate candidate by petition the process is as follows you may nominate a candidate by petition of 2 5 of the membership 350 members should you wish to engage in this process the petition must be submitted to the AANAC office by January 7 2013 If you have questions about this process do not hesitate to contact me at rminnema aanac org Sincerely Ruth Munere Ruth Minnema RN MA C NE RAC CT Chair Board of Directors aanac org 800 768 1880 AANAC LTC LEADER 11 15 2012 2012 AANAC No part of this publication may be reproduced without written permission from AANAC The information presented is informative and does not constitute direct legal or regulatory advice AANAC Board of Directors Ruth Minnema RN MA C NE RAC CT Chair Peter Arbuthnot aa BA RAC CT Vice Chair Carol Maher RN BC RAC CT Secretary Patrice Macken MBA RHIA LNHA RAC CT Treasurer Susan Duong RN BSN NHA RAC CT C NE Gail Harris RN BSN RAC CT C NE Joanne Powel
9. chopharmacological medications specifically antipsychotic medications What it all means Psychoactive drugs are such a focus that every facility needs to have systems in place for the monitoring of psychoactives making sure that you have appropriate diagnoses and appropriate dose reduction recommends Boyer Dementia Hand in hand with the stronger focus on antipsychotic medications is a stronger focus on how the facility addresses the behavioral and psychological continued on page 4 AANAC LTC LEADER 11 15 2012 2012 AANAC No part of this publication may be reproduced without written permission from AANAC The information presented is informative and does not constitute direct legal or regulatory advice Traditional Survey Guidance continued from page 3 symptoms of dementia again starting in the entrance conference says Deb Myhre rn c ne Rac mT a consultant with Ankeny lowa based Continuum Health Care Services Surveyors will ask the administrator to designate a staff member to discuss such special features of the facility s treatment programs such as excerpted from 12 45 NH e Does the facility have special care units for residents with heavy clinical care needs people with dementia or those receiving specialized rehabilitation services What individualized care and services are provided for residents with dementia How are staff educated and trained to care for people with dement
10. e rolling seven day schedule with the early COT the next COT ARD will out of compliance p 2 73 Default for Late PPS Assessments One of the most impactful changes is the new guidance on how to apply default days when an assessment is late Specifically for a scheduled assessment default is applied for the number of days that an ARD is late rather than back to the beginning of the payment period This is a very positive change for providers as default days are limited Here is the clarification If the ARD on the late assessment is set for prior to the end of the period during which the late assessment would have controlled the payment had the ARD been set timely and or no intervening assessments have occurred the SNF will bill the default rate for the number of days that the assessment is out of compliance This is equal to the number of days between the day following the last day of the available ARD window including grace days when appropriate and the late ARD including the late ARD The SNF would then bill the Health Insurance Prospective Payment System HIPPS code established by the late assessment from the time that the assessment would have controlled payment pp 2 73 and 6 53 If the ARD of the late assessment is set after the end of the period during which the late assessment would have controlled payment or in cases where an intervening assessment has occurred and the resident is still o
11. ia including how to prevent or address the behavioral and psychological symptoms of dementia BPSD How does the facility monitor the use of psychopharmacological medications specifically antipsychotic medications Surveyors will also evaluate non pharmacological interventions for emotional and behavioral issues points out Boyer For example during the initial tour Task 3 when surveyors observe for possible quality of care and or quality of life concerns 12 45 NH tells them to consider communication interactions and approach techniques used by staff also will dig a little deeper looking for inconsistencies in how the care plan flows out of the triggered Care Areas Assessments and MDS coding she stresses For example during resident reviews surveyors will determine if facility staff has properly and accurately assessed Surveyors will also evaluate non pharmacological interventions for emotional and behavioral issues points out Boyer when addressing residents emotional and behavioral needs such as crying out pacing etc including staff availability and response time and the resident s reaction to these interventions The MDS CAAs and care plan As they have in the past surveyors will determine if documentation supports the MDS coding of at least two QMs from the Resident Level QM Report during each comprehensive care review Subtask 5C says Boyer However they residents through
12. illing process were detailed in chapter 2 pages 49 50 Combining COT With Scheduled Assessment Optional If day seven of the COT observation period falls within the ARD window of a scheduled PPS assessment the SNF staff may choose to complete the PPS assessment alone by setting the ARD of the scheduled PPS assessment for an allowable day that is on or prior to day seven of the COT observation period If the scheduled assessment ARD falls on or before day seven of the rolling COT window the window is reset p 2 51 Use this option when the RUG is estimated to drop If it is not facility staff may choose to combine the COT ARD with the scheduled assessment and receive a higher RUG back to the beginning of the COT window aanac org 800 768 1880 Clarification on Resident Interviews The ability to carry resident interviews from a previous assessment to the current assessment is a continuation of previous updates and a welcome reduction in frequency p 2 52 CMS has indicated that when using a prior interview the person who originally did the interview and attested to its accuracy must attest to its accuracy on the current assessment and enter the date the interview originally was completed as indicated on that prior assessment Default for Early PPS Assessments It is critical to note that when a COT is early the rolling ARD window is reset with the ARD of the early COT If facility staff don t recalculate th
13. l NHA RHIA Carol Siem Msn RN BC GNP RAC CT Diana Sturdevant ms GCNS BC AANAC Expert Panel AANAC is pleased to introduce you to our panel of volunteer reviewers who represent the best and the brightest in our field Betty Frandsen RN NHA MHA C NE Nichols NY Robin L Hillier CPA STNA LNHA RAC MT President RLH Consulting Becky LaBarge RN RAC MT Vice President Clinical Reimbursement The Tutera Group Deb Myhre RN C NE RAC MT Nurse Consultant Continuum Health Care Services Ron Orth RN NHA RAC MT Clinical Reimbursement Solutions LLC Milwaukee WI Andrea Otis Higgins RN MLNHA CDONA CLNC RAC MT CEO Administrator St Andre Healthcare Biddeford ME Rena R Shephard MHA RN RAC MT C NE AANAC Executive Editor President RRS Healthcare Consulting Services San Diego CA Judy Wilhide Brandt RN RAC MT C NE Regional MDS Medicare Consultant President Judy Wilhide MDS Consulting Inc All the articles in this LTC Leader can also be found on the aanac org website aanac org 800 768 1880 A Therapy Service over a Holiday Weekend Holidays are a challenge The doctor s orders for therapy say 5d wk because that is the requirement to meet skilled guidelines for Medicare A Plus if they have 3 days in a row with no therapy provided and then end of therapy MDS has to be done So therapy either comes in on the holiday or makes it up on the weekend For Thanksgiving our therapy is goi
14. n Part A the provider must still complete the assessment The ARD can be no earlier than the day the error was identified The SNF must bill all covered days during which the late assessment would have controlled payment had the ARD been set timely at the default rate regardless of the HIPPS code calculated from the late assessment see Section 2 8 pp 2 74 and 6 53 Missed PPS Assessment One of the most painful results of the complicated PPS scheduling is provider liability when the facility cannot be paid for Medicare provided days This occurs when facility staff fail to set the ARD timely for either a scheduled or unscheduled PPS assessment and the resident has discharged or is no longer on Medicare If the SNF fails to set the ARD of a scheduled PPS assessment prior to the end of the last day of the ARD window including grace days and the resident was already discharged from Medicare Part A when this error is discovered the provider cannot complete an assessment for SNF PPS purposes and the days cannot be billed to Part A An existing OBRA assessment except a stand alone discharge assessment in the QIES ASAP system may be used to bill for some Part A days when specific circumstances are met See Chapter 6 Section 6 8 for greater detail In the case of an unscheduled PPS assessment if the SNF fails to set the ARD for an unscheduled PPS assessment within the defined ARD continued on page 3 AANAC LTC L
15. nd alone End of Therapy OMRA EOT anda stand alone Start of Therapy OMRA SOT Facility staff must set the ARD for a day within the allowable ARD window for that assessment type such as day seven of the COT rolling window but may only do so by day two following the day after the window has passed p 2 40 continued on page 2 WWW AANAC ORG Update Traditional Survey Guidance Effective December 1 2012 Caralyn Davis Staff Writer The revised traditional survey process explained in survey and certification memo 12 45 NH suggests that surveyors will place an increased emphasis on three key areas Antipsychotic medications Facilities already have to give surveyors a significant amount of information about their residents use of psychoactive medications The CMS 802 Roster Sample Matrix asks for a list of all current residents who receive psychoactive medications but have no psychiatric condition In addition the CMS 672 Resident Census and Conditions of Residents asks for the total number of current residents who receive any psychoactive medications as well as individual counts for antipsychotics and other related drugs During the entrance conference Task 2 the facility will be asked for a listing of all residents who are receiving or have received antipsychotic medications in the last 30 days However CMS is pushing an even stronger focus on antipsychotic medications from the outset of the survey says Pa
16. ng to do more minutes on other days and come in on the holiday and do 15 mins per resident so it s a shortened day This way residents can still do family things if they desire There are no Medicare holidays We are expected to provide necessary services to our residents regardless of the day It is certainly a challenge Carol Maher rn Bc Rac mt cmahero121 earthlink net Opening Assessment After Discharge Is that true you can open an assessment after they discharge When did they change that Where can I find this rule The last I knew if a Medicare A resident was discharged to the hospital you could not open a5 day assessment after they left you have to bill provider liable Please someone clarify The rule did not change We cannot open assessments after a resident discharges from Medicare A except for the 2 day flexibility period for unscheduled assessments such as COTs Carol Maher rn Bc Rac mt cmahero121 earthlink net Using a Quarterly to replace a Missed Assessment We have a Med A resident who was in a swing bed for 19 days prior to admission We skilled her for new g tube with 100 of nutrition for the remaining 81 days It turns out she was billed out as in patient for the 19 days I did PPS assessments all the way to the 60 day I also did a quarterly assessment on day 92 which does calculate a RUG level Is there anything I can do to bill a RUG for days 91 100 or due we just bill default She was admitted on 3 2
17. re are any concerns related to dining as expressed by the resident or family member or if there are concerns about the resident such as unplanned weight loss Phase 2 resident samples are selected onsite at the facility part way through the survey when surveyors have collected enough information to determine the focus of the remainder of the survey This review focuses only on those areas of concern for which the team requires additional information i e new concerns and or to continue further investigation of Phase 1 concerns when Phase 1 reviews proved inconclusive or when necessary to determine scope of a problem For example if the team needs additional information concerning facility compliance with the requirements for tube feeding review only those RAI areas related to tube feeding make observations of nutritional status complications and techniques of tube feeding and interview residents family and staff concerning related areas All residents selected for comprehensive reviews are selected by the team during Phase 1 sample selection Residents selected for focused reviews closed record reviews individual and family interviews may be selected during Phase 1 or Phase 2 Source Compiled from multiple sections in S amp C memo 12 45 NH AANAC LTC LEADER 11 15 2012 2012 AANAC No part of this publication may be reproduced without written permission from AANAC The information presented is informative and
18. tricia Boyer msm Rn NHA president of the operational consulting firm Boyer and Associates in Brookfield Wis During the entrance conference Task 2 the facility will be asked for a listing of all residents who are receiving or have received antipsychotic medications in the last 30 days This list will need to be provided within an hour or as soon as possible following the entrance conference according to 12 45 NH In Task 4 sample selection surveyors will compare continued on page 3 MDS 3 0 User s Manual Update continued from page 1 Optional Completion of the EOT The EOT is not required unless the resident remains skilled for at least three days after the last day of therapy If the RUG would be higher due to the EOT completion facility staff may choose to complete it If so then the EOT may be combined with the Discharge assessment if those days coincide p 2 48 EOT With Therapy Resumption In cases where therapy resumes after the EOT OMRA is performed and the resumption of therapy date is no more than five consecutive calendar days after the last day of therapy is provided an EOT with resumption EOT R can be completed The therapy services must be expected to resume at the same RUG IV classification level and with the same therapy plan of care that had been in effect prior to the EOT OMRA p 2 49 Billing Instructions for End of Therapy With Resumption Instructions for handling the EOT B
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