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.”
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- 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:
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- Modification
- Inactivation
- 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:
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- 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:
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- 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:
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- 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
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