Some skilled nursing facilities (SNFs) are concerned about accurate payment when a resident unexpectedly discharges and the Brief Interview for Mental Status (BIMS) has not yet been completed.
However, they should be just as concerned about the PHQ-9.
phq-9

The PHQ-9 identifies depressive symptoms to be captured on the MDS. The interview follows the same basic rules as the BIMS.

  • Both interviews should be conducted, preferably on the day of or the day before the ARD.
  • The provider cannot complete the Staff Assessment of Resident Mood if the resident interview should have been conducted but was not done. For example, A resident is admitted, and the 5- day ARD is set for day 8. The social worker would not be conducting the PHQ-9 interview until day 7 or 8, but what happens when the resident is discharged unexpectedly on day 5?
  • CMS does not allow the staff assessment to be done for an interviewable resident when an unplanned discharge occurs before the PHQ-9 is completed. That means the payment will automatically default into non-depressive case-mix classification in the nursing component, which could result in a significant loss.

Without the BIMS, there is a potential loss of approximately $15 per day. While, without the PHQ-9, there is a potential loss of approximately $40 or more a day, depending on the local base rate.

With the advent of PDPM, some facilities began completing the BIMS interview upon admission to use in case of an unexpected discharge. The facility should consider adding the PHQ-9 to the BIMS for admission assessments

Interviewing on the day of admission may be even more critical because:

  • CMS makes no provision for doing the staff assessment instead of the PHQ-9 for unexpected discharges the way it does for the BIMS.
  • From a clinical standpoint, the clinical team being aware of depressive symptoms upon admission can trigger earlier treatment and person-centered care planning approaches to help manage the depression.

Keep in mind the RAI manual states the BIMS and PHQ-9 interview is to be completed the day before or of the ARD. If these interviews are completed upon admission, they should not be used for an assessment with a later date. For example, an assessment with an ARD set for day 8 could not use interviews from the day of admission.

The best practice is to conduct another interview on the day before or the day of the ARD.  Following this practice ensures an accurate MDS assessment and accurate reimbursement.

For the BIMS and PHQ-9 tools, see: https://mds-consultants.com/minimum-data-set-forms/

For more information:  https://downloads.cms.gov/files/mds-3.0-rai-manual-v1.17.1_october_2019.pdf