CMS Issues RAI Manual Updates Effective October 1, 2013

 CMS recently posted the fall updates to the RAI User’s Manual, which take effect on October 1. Among the important changes providers need to be familiar with are new items in Section K (swallowing/nutritional status) and Section O (special treatments, procedures and programs).  Additional clarification is also provided in Section G (activities of daily living) and on setting the assessment reference date (ARD) for Discharge assessments.  These changes will impact classification of residents into RUGs for payment purposes and should be reviewed carefully by center staff involved in care documentation and MDS assessments and coding.

In Section K, a new item is added to capture information about caloric and fluid intake via parenteral feeding, tube feeding or intravenously. 

In Section O, two new pieces of information are being captured.  First, centers will be required to report co-treatment minutes by entering the total number of minutes each discipline of therapy was administered to the resident in co-treatment sessions in the last 7 days. Second, centers will now be required to report the number of distinct calendar days on which at least 15 minutes of therapy services were provided in the past 7 days.

In Section G, item G0110, Activities of Daily Living (ADL), the manual updates relate to the “rule of three” and the use of the ADL Self-Performance Algorithm. Over the past several months, CMS has commented in a number of different venues regarding the intended application of the rule of three described in the RAI manual.  In these new updates, CMS clarifies the instruction that as the first step to determining the appropriate coding for this section, “When an activity occurs three or more times at any one level, code that level.” If this step applies to the situation, providers are instructed not to go on to apply the algorithm. New examples are included in this section to illustrate correct coding.
Finally, with regard to discharge assessments, CMS clarifies  that the ARD for a discharge assessment is always the date of discharge.

CMS also released a separate memorandum describing the transition process for implementation of these new items, effective October 1.  The transition policies will apply to determination of RUGs for individuals with assessment reference dates between October 1 and October 13.