Exactly when skilled nursing facilities are allowed to dash discharge goal items in Section GG (Functional Abilities and Goals) without imperiling their ability to meet the data submission threshold requirement for the Skilled Nursing Facility Quality Reporting Program (SNF QRP) remains a concern for many providers. Officials with the Centers for Medicare & Medicaid Services (CMS) offered the following responses to questions submitted by AANAC staff, providing some clarification about dash usage for Section GG goals for fiscal year (FY) 2020 data collection occurring in calendar 2018:
1. For the FY 2019 APU data collection, SNFs only had to code one of the 12 Section GG discharge goal items. As long as one was coded, up to 11 Section GG discharge goal items could be dashed. Is this guidance still correct for data collection for the first three quarters of calendar 2018 data collection for the FY 2020 APU determination?
2. If the above answer remains that only one discharge goal must be coded (though more can be coded), does that change with the implementation of MDS 3.0 Version 1.16.0 for CY Q4 2018? Effective Oct. 1, will you still only require that at least one of current Section GG discharge goal items be coded (not dashed) to count toward threshold compliance? I ask because I noticed that, as of Oct. 1, you are changing the status of some SNF QRP QM risk-adjustment items that have not previously been required items (e.g., K0200A/B) for threshold compliance, and you're making them count toward threshold compliance.
Response: The data elements identified in the SNF QRP Table for Reporting Assessment-Based Measures for the FY 2020 SNF QRP APU (including K0200A and K0200B) are the data elements needed to calculate the SNF QRP quality measures and are defined as standardized data elements. This table includes all of the data elements required for determination of the APU compliance threshold. However, for APU compliance a minimum of one Section GG self-care or mobility discharge goal item will be required for data collection effective 10/1/2018 through 12/31/18 as for data collection effective 1/1/18 through 9/30/18.
3. Effective Oct. 1, you are adding several new discharge goals, including: GG0130E2, GG0130F2, GG0130G2, GG0130H2, GG0170A2, GG0170G2, GG0170I2, GG0170L2, GG0170M2, GG0170N2, GG0170O2, and GG0170P2. Will all of these new discharge goal items need to be coded to count toward threshold compliance, or does only one from this set of new discharge goals need to be coded as well?
Response: For the SNF Quality Reporting Program (QRP) effective with admissions and discharges beginning 10/1/2018, a minimum of one self-care or mobility discharge goal must be coded. However, facilities may choose to complete more than one self-care or mobility discharge goal. Code the resident’s discharge goal(s) using the six-point scale.
Effective 10/1/18, use of the “activity was not attempted” codes (07, 09, 10, and 88) will be permissible to code discharge goal(s). At least one Discharge Goal must be coded for either Self-Care or Mobility, codes 01 through 06 or 07, 09, 10, or 88 selected from any one or more Section GG self-care goal data elements (GG0130A2 through GG0310H2) or mobility discharge goal data elements (GG0170A2 through GG0170S2) identified on MDS Version 1.16.0. Use of a dash is permissible for any remaining self-care or mobility goals that are not coded. Using the dash in this allowed instance after the coding of at least one goal does not affect Annual Payment Update (APU) determination. Since a dash (“-”) indicates “No information,” CMS expects dash use to be a rare occurrence.
Editor's note: At the Aug. 1 SNF QRP training session, officials noted that the measure specifications to calculate the numerator for the SNF QRP quality measure Application of Percent of Long-Term Care Hospital (LTCH) Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function will be updated to reflect that at least one of the 24 total discharge goal items that will be collected effective Oct. 1, 2018, must be coded (i.e., not dashed), making the calculation for this QM consistent with APU data collection requirements. When available, the updated SNF QRP Measure Calculations and Reporting User’s Manual will be posted here.
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