What does the NAC do when they identify an error on an MDS assessment? The answer is correct the identified error. Any error that incorrectly represents the resident’s status needs to be corrected. One would think correcting an MDS error would be a “simple” process, but MDS corrections can be a multifaceted undertaking.

When an MDS error is identified, the NAC must determine what type of error has occurred and if the MDS assessment has been submitted to iQIES (Internet Quality Improvement and Evaluation System). The MDS Correction Policy – located in Chapter 5.3 of the RAI User’s Manual – describes corrective actions for MDS assessments accepted into iQIES and assessments prior to being submitted to iQIES.

 

Correcting MDS Records Prior to iQIES Submission

The NAC has 7 days to encode and edit an MDS assessment after the assessment has been completed. During this 7-day encoding period, the NAC can correct the MDS data element coding item(s) but the observation/look-back period must not change with the correction.

If there are errors noted after the encoding and editing period, the NAC has 14 days for correction. Entries, discharges, death in facility, and PPS records need to be corrected and submitted to iQIES. For Quarterly and Comprehensive MDS assessments, the NAC must first distinguish whether the error is significant or minor. “Errors that inaccurately reflect the resident’s clinical status and/or result in an inappropriate plan of care are considered significant errors.”

    • Minor errors in the Quarterly or Comprehensive assessment will be corrected and then submitted to iQIES
    • Significant errors will be corrected on the current MDS assessment and submitted to iQIES; a Significant Change in Status or Significant Correction in Prior Assessment must be completed/submitted and updated in the care plan as needed

 

Correcting MDS Records Accepted in iQIES

A correction can be submitted for any accepted record within 2 years of the target date of the record for facilities that are currently still open. If the facility has been closed, then it is 2 years from the closure date. Three corrective options are listed in the MDS Correction Policy in Chapter 5.3 of the RAI User’s Manual:

    1. Modification
    2. Inactivation
    3. Manual Deletion

 

Modification

A modification of an MDS assessment is completed when the MDS item(s) are incorrect due to clinical or demographic errors which consists of:

    • transcription errors
    • data entry errors
    • software product error
    • item coding errors
    • other errors requiring modification

When determining if a modification is required for the current MDS assessment the NAC must distinguish if the error is minor or significant. The steps listed previously still apply for both.

 

Inactivation

An inactivation of an MDS assessment is completed when the event of the MDS assessment did not occur. The inactivation will move the existing MDS record from active files to an archived file in iQIES, which will exclude the record from facility reporting. Inactivations should only be completed on rare occasions and for certain conditions.

If the NAC decides to inactivate an assessment, they may need to complete a new assessment with a new ARD and observation period according to the required MDS assessment schedules.

 

Manual Deletion

A manual deletion is the removal of the MDS record completely from iQIES. There are 4 MDS assessment error occurrences that cannot be corrected with a Modification or Inactivation request and therefore require a Manual Deletion:

    • Incorrect unit certification or licensure designation (A0410)
    • Incorrect State Code (STATE_CD) or Facility ID (FAC_ID)
    • Record submitted was not for OBRA or Medicare PPS purposes
    • Test records incorrectly submitted instead of production records

The NAC/facility must contact the State Agency prior to completion of the MDS 3.0 Individual Assessment Correction/Deletion Request Form. The manual deletion form is available in iQIES for download.

 

MDS Correction Request – Section X

MDS Section X is required for Modifications and Inactivations.

Section X is only completed if Item A0050, Type of Record, is coded a 2 (Modify existing record) or a 3 (Inactivate existing record). In Section X, the facility must reproduce the information EXACTLY as it appeared on the existing erroneous record, even if the information is incorrect. This information is necessary to locate the existing record in the Internet Quality Improvement and Evaluation System (iQIES).

Included in this section is the reason the modification and inactivation is being completed. The NAC enters the total number of correction requests on the current MDS assessment, and the RN NAC signs and dates the attestation of the modification/inactivation request in this section.

 

NAC Strategies for MDS Corrections

MDS corrections should be completed when identified by the NAC for an accurate reflection of the resident’s status, reimbursement, and quality of care. Some strategies for success:

    • Determine what type of MDS error occurred and submission status
    • Identify what type of correction is needed
    • Distinguish whether the error is minor or significant
    • Consider other MDS assessments that may need to be completed
    • Contact state RAI coordinator with any questions

 

 

More Resources

Explore More Posts from MDS Consultants

Reimbursement Concerns

Maximizing Case Mix with Special Programs: Respiratory Therapy and Restorative Nursing

Case mix is essential in skilled nursing facilities as it impacts both reimbursement and the care provided. Two key programs that significantly impact case mix scores when properly implemented and documented are Respiratory Therapy and Restorative Nursing. Both...

Strategic Admissions: The Path to Optimized Medicaid Reimbursement

Medicaid reimbursement plays a significant role in the financial health of long-term care facilities, particularly those serving a high percentage of Medicaid residents. While it may not be the sole source of revenue, it is an important component that supports the...

Interim Payment Assessment (IPA) – To do or not to do?

The Patient-Driven Payment Model took effect in October of 2019. Along with this change came the optional IPA. We are now five years into this change and questions still arise on when to complete an IPA. The decision of when to complete lies with the team at the...

Resident Interviews – What are you doing to capture the data?

Effective October 1, 2023, several resident interviews were added to or updated on the MDS. Interview items in Section A and changes to the interviews in Section D, J, and Q have been implemented. Each of the interviews can be a great steppingstone in your path to...

Social Determinants of Health (SDOH) – A Global Initiative Important to Skilled Nursing Providers

The Centers for Medicare & Medicaid Services’ (CMS) Office of Mental Health report CMS Framework for Health Equity 2022 and 2032 states that health equity is defined by the attainment of the highest level of health for all people, where everyone has a fair and...

Read more on Toolbox Essentials

SNF Physician Certifications for Medical Review

One of the requirements of payment is a valid Physicians Certification for Medicare part A services. If SNF certifications and re-certifications are not completed and signed following CMS regulations, then the facility is at risk of losing payment for an entire claim...

Focused Infection Control Surveys and Directed Plan of Correction

It's a dreary Monday morning, and the state surveyors walk into your facility to conduct a Focused Infection Control survey. You and your team have been trying your hardest to comply with infection control procedures throughout the pandemic. At the end of the survey,...

New Advanced Beneficiary Notice

Is your facility using the proper ABN form? The Centers for Medicare & Medicaid Services (CMS) recently updated the Advanced Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131. The new ABN will be mandatory for use on 1/1/2021, but the new form can be...

Covid-19 and Skilled Status

In late June, CMS addressed two issues and posted MDS 3.0 Final Item Sets (V1.17.2).  The two edits were changes to facilitate the calculation of Patient-Driven Payment Model payment codes on OBRA assessments for states that wish to have this calculation performed. ...

Mind Your PHQs

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. The PHQ-9...

MORE from MDS Experts

What is an MDS Coordinator?

"What do you do for a living?" It may not surprise you that when asked this question, most MDS Coordinators struggle to come up with an answer. The reality is that MDS Coordinators fully understand what this multifaceted job entails, but are at a loss of how to put it...

From the MDS to RAI System Management

With the introduction of the Minimum Data Set (MDS) through the Omnibus Budget Reconciliation Act (OBRA) of 1987, Centers for Medicare and Medicaid (CMS) implemented a method of standardized, comprehensive, and reproducible data collection for long term care residents...

Maximizing Case Mix with Special Programs: Respiratory Therapy and Restorative Nursing

Case mix is essential in skilled nursing facilities as it impacts both reimbursement and the care provided. Two key programs that significantly impact case mix scores when properly implemented and documented are Respiratory Therapy and Restorative Nursing. Both...

Strategic Admissions: The Path to Optimized Medicaid Reimbursement

Medicaid reimbursement plays a significant role in the financial health of long-term care facilities, particularly those serving a high percentage of Medicaid residents. While it may not be the sole source of revenue, it is an important component that supports the...

Internet Quality Improvement and Evaluation System (iQIES): A New Age

Just when we thought we had a handle on QIES (Quality Improvement and Evaluation System), the Centers for Medicare & Medicaid Services (CMS) transitioned to the Internet Quality Improvement and Evaluation System (iQIES) in 2023.   Reports and Roles Reports...