CMS officials reviewed the changes included in the latest MDS 3.0 Draft Item Set and addressed callers’ concerns about the new assessment tool during the SNF Open Door Forum on May 28. Two areas of focus were the new Care Area Triggers (CAT) and ensuring the MDS 3.0 will work efficiently with RUG-III.
Karen Schoeneman, of CMS’ division of nursing homes, clarified the differences between the Resident Assessment Protocols (RAP) on the MDS 2.0 and the CATs on the MDS 3.0. The CAT process will be basically the same as the RAP process, but instead of using a set framework for the additional assessment (a RAP), facilities will be able to choose the clinical process guideline they wish to use (a CAT).
According to Schoeneman, RAPs are not comprehensive and do not cover every condition or issue a resident may have. “The internet contains countless resources related to clinical practice guidelines for any particular issue that might be triggered by the MDS assessment process,” Schoeneman said. “CMS decided that it was time to let the providers be free to choose and use the clinical practice guideline or authoritative source material they wish to complete that in-depth assessment process.”
The updated RAI Users’ Manual will include a list of government websites with free clinical practice guidelines that have been researched and are authoritative, which providers can use. Providers will still have the option of using CMS’ clinical practice guidelines, as the updated manual will also include RAP outlines as they are in their current state.
Since states are not required to implement RUG-IV for their Medicaid processing, CMS has been working to ensure that the MDS 3.0 data will work with RUG-III without changing the distribution of patients who classify into the different categories. “So far, we have crosswalked items from the MDS 3.0 to the RUG-III system and have been able to work that there is no impact overall to how patients categorize,” said CMS official Ellen Berry. Information about this analysis is expected to be posted on the MDS 3.0 page of CMS’ website within the next two weeks.
CMS official Thomas E. Dudley, MS, RN, confirmed that MDS 3.0 implementation efforts remain on track and said that CMS does not anticipate any major changes between this draft and final version to be released in October.