Providers have been collecting data for MDS section GG (Functional Abilities and Goals) since October 2016, largely to meet the data submission threshold for the Skilled Nursing Facility Quality Reporting Program (SNF QRP). “In many SNFs, nursing has generally abdicated responsibility for section GG to the therapy department because there is no payment attached to section GG under the RUG-IV case-mix classification system,” says Joel VanEaton, BSN, RN, RAC-MT, vice president of compliance and regulatory affairs for Broad River Rehab in Asheville, NC.
“That’s a big mistake when it comes to the Patient-Driven Payment Model (PDPM), which implements on Oct. 1,” says VanEaton. “To correctly define the resident’s functional profile in section GG, you have to figure out how to shift from that therapy-only paradigm to a paradigm of true collaboration, particularly among the MDS department, nursing, and rehab.”
“The most significant problem with section GG is that coding often isn’t interdisciplinary,” agrees Tracy Montag, BSN, RN, RAC-MT, clinical consultant with the Senior Living Services Consulting Group at RKL LLP in York, PA. “There are still a lot of facilities that don’t look at usual performance over three days because coding is so therapy-driven. For example, for the 5-day PPS MDS, they input information directly into section GG from the documentation the therapist completes during the therapy evaluation. Sometimes facilities don’t even have information collected for some components of section GG because therapy is not seeing the resident for those components.”
To improve section GG coding accuracy, nurse assessment coordinators (NACs) should consider the following steps: