• OIG to Look at Medicare Part D Payments in SNF Stays and Nursing Home Background Checks (1/21)

    By OIG - January 15, 2021

    Medicare Part D Payments During Covered Part A SNF Stay

    Medicare Part A prospective payments to skilled nursing facilities (SNFs) cover most services, including drugs and biologicals furnished by the SNF for use in the facility for the care and treatment of beneficiaries. Accordingly, Medicare Part D drug plans should not pay for prescription drugs related to posthospital SNF care because these drugs are already included in the consolidated payment for Part A SNF stays. We will determine whether Medicare Part D paid for drugs that should have been paid under Part A SNF stays.

     

    Announced or Revised

    Agency

    Title

    Report Number(s)

    Expected Issue Date (FY)

    January 2021

    Centers for Medicare and Medicaid Services

    Medicare Part D Payments During Covered Part A SNF Stay

    W-00-21-35866

    2022

     

    Background Checks for Nursing Home Employees

    Federal regulation 42 CFR 483.12(a)(3) provides beneficiaries who rely on long-term care services with protection from abuse, neglect, and theft by preventing prospective employees with disqualifying offenses from being employed by these care providers and facilities. The National Background Check Program was enacted by legislation in 2010 to assist States in developing and improving systems for conducting Federal and State background checks. Prior OIG work has shown that not all States complied with the National Background Check Program for Long-Term Care Providers. We will determine whether Medicaid beneficiaries in nursing homes in selected States were adequately safeguarded from caregivers with a criminal history of abuse, neglect, exploitation, mistreatment of residents, or misappropriation of resident property, according to Federal requirements. 

     

    Announced or Revised

    Agency

    Title

    Report Number(s)

    Expected Issue Date (FY)

    January 2021

    Centers for Medicare and Medicaid Services

    Background Checks for Nursing Home Employees

    W-00-21-31553

    2022

     

     

     


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  • The importance of device selection, education, and training for appropriate and effective inhalation therapy in COPD

    By Shahin Sanjar, PhD., Sunovion Pharmaceuticals Inc. - January 13, 2021

    Inhalation treatment of respiratory conditions such as asthma and COPD is the predominant mode of therapy for the simple and logical reason that applying pharmacological agents to the target organ reduces the drug dose, maintains good efficacy, as well as reduces potential systemic adverse effects. To this end, there are now multiple systems for delivering therapeutic agents either as single or fixed dose combinations of two or three agents. The focus of this article is on the delivery devices and potential challenges with multiple device options rather than the therapeutic agents. It is important to recognize that even the best therapeutic agents cannot be effective unless they are delivered to the correct target organ or site. 


    Given the wealth of treatment and delivery options, it is surprising that treatment of COPD remains less than optimal and reported rates of device use errors remain high (Sanchis J et al. 2016, Molimard et al. 2017). This topic has been broadly discussed in the latest Global Initiative for Obstructive Lung Disease (GOLD 2021) report, with an emphasis on effective training and appropriate device selection for COPD patients. In a recent study, only 23% of patients discharged from the hospital demonstrated appropriate use of dry powder inhalers (Sulaiman et al. 2017). It is important to note that despite significant improvements in device design and a greater understanding of drug delivery issues, such as aerodynamics of particle flow as well as optimal particle size for pulmonary delivery, device error rates have remained high for decades (Sanchis et al. 2016). It is now well-recognized that education and training are key components of proper inhaler use, which requires regular assessment and the implementation of the “teach back” method (Dantic 2014). The importance of continued assessment is highlighted by the observation that the training effect does not persist (Press et al. 2016).

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  • Section M: Skin Conditions - Assessment and Coding of Pressure Ulcers/Injuries: CMS Web-Based Training (1/21)

    By MX - January 13, 2021
    The Centers for Medicare & Medicaid Services (CMS) is offering a web-based training course that provides an overview of the assessment and coding of pressure ulcers/injuries. This 90-minute course is intended for providers in Home Health Agencies (HHAs), Inpatient Rehabilitation Facilities (IRFs), Long-Term Care Hospitals (LTCHs), and Skilled Nursing Facilities (SNFs), and is designed to be used on demand anywhere you can access a browser.
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  • Cross-Setting QRP Data Elements and Quality Measures: CMS Web-Based Training (1/21)

    By CMS - January 13, 2021

    From Data Elements to Quality Measures – Cross-Setting QRP Web-Based Training

    The Centers for Medicare & Medicaid Services (CMS) is offering a web-based training course that provides a high-level overview of how data elements within CMS patient/resident assessment instruments are used to construct quality measures (QMs) across post-acute care (PAC) settings. The PAC settings included are those covered under the Centers for Medicare & Medicaid Services (CMS) Quality Reporting Programs (QRPs) for Home Health Agencies (HHAs), Inpatient Rehabilitation Facilities (IRFs), Long-Term Care Hospitals (LTCHs) and Skilled Nursing Facilities (SNFs). Information covered will include a short review of the QRPs’ cross-setting quality measures (QM), how data elements feed into these cross-setting QMs, how QMs are calculated and appear on QM reports and how to access and use this data for quality improvement. 

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  • Contract Year 2022 Medicare Advantage and Part D Final Rule (1/21)

    By CMS - January 13, 2021

    The Centers for Medicare & Medicaid Services (CMS) issued a final rule that further advances the agency’s efforts to strengthen and modernize the Medicare Advantage and Part D prescription drug programs. The changes finalized today are generally effective for the 2022 plan year and will potentially lower enrollee cost sharing on some of the most expensive prescription drugs. This final rule will allow enrollees to know in advance and compare their out-of-pocket payments for different prescription drugs. The changes will result in an estimated $75.4 million in savings to the federal government over ten years.

    “The changes in this final rule provide desperately needed transparency on the out-of-pocket costs for prescription drugs that have been obscured for seniors,” said CMS Administrator Seema Verma. “It will strengthen Part D plans’ negotiating power with prescription drug manufacturers so American patients can get a better deal.”

    As part of the administration’s commitment to promoting price transparency and lowering prescription drug prices, the final rule will require Part D plans to offer a real-time benefit comparison tool starting January 1, 2023, so enrollees can obtain information about lower-cost alternative therapies under their prescription drug benefit plan. Enrollees would be able to compare cost sharing to find the most cost-effective prescription drugs for their health needs. For example, if a doctor recommends a specific cholesterol-lowering drug, the enrollee could look up what the co-pay would be and see if a different, similarly effective option might save the enrollee money. With this tool, enrollees will be better able to know what they will need to pay before they are standing at the pharmacy counter. This follows a similar CMS requirement that Part D plans support a prescriber real-time drug benefit tool that went into effect January 1, 2021. Congress codified a similar requirement for prescriber real-time benefit tools in the recently enacted Consolidated Appropriations Act, 2021 (Public Law No. 116-260).

    In the Medicare Part D program, enrollees choose the prescription drug plan that best meets their needs. Many plans offering prescription drug coverage place drugs into different “tiers” on their formularies. Today, all drugs on a plan’s specialty tier – the tier that has the highest-cost drugs – have the same level of cost sharing. Under the final rule, CMS is allowing Part D plans to have a second, “preferred” specialty tier with a lower cost sharing level than their other specialty tier. This change gives Part D plans more tools to negotiate better deals with manufacturers on the highest-cost drugs and lower out-of-pocket costs for enrollees in exchange for placing these products on the “preferred” specialty tier.

    Under the Part D program, plans currently do not have to disclose to CMS the measures they use to evaluate pharmacy performance in their network agreements. CMS has heard concerns from pharmacies that the measures plans use to assess their performance are unattainable or otherwise unfair. The measures used by plans potentially impact pharmacy reimbursements. Therefore, CMS is requiring Part D plans to disclose pharmacy performance measures to CMS, which will enable CMS better understand how such measures are applied. CMS will also be able to report pharmacy performance measures publicly to increase transparency on the process and to inform the industry in its new efforts to develop a standard set of pharmacy performance measures.

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  • World Health Organization: Updated COVID-19 Interim Guidance for LTC Facilities (1/21)

    By WHO - January 12, 2021
    Infection prevention and control guidance for long-term care facilities (including NFs and SNFs) in the context of COVID-19 Interim guidance

    8 January 2021

    This document is an update of the guidance published on 21 March 2020 and contains new evidence and guidance, including the following:

    • updated results from published studies on:
      • the epidemiology and extent of SARS-CoV-2 infection among residents and staff in long-term care facilities (LTCFs);
      • the effectiveness of infection prevention and control (IPC) precautions to prevent SARS-CoV-2 transmission in LTCFs;
      • the impact of IPC precautions on mental and physical health and well-being of older people, and in particular people with dementia or other mental health or neurological disorders;
    • updated advice on IPC precautions to prevent the spread of SARS-CoV-2 and to protect health workers and caregivers of patients with suspected or confirmed COVID-19 in LTCFs;
    • advice on early detection of and testing for SARS-CoV-2 among residents and staff in LTCFs;
    • advice on policies for visitors to LTCFs and additional considerations on minimizing the mental and physical health impacts of restrictions and IPC precautions implemented in the context of COVID-19.
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  • PPS Discharge Assessments: Why NACs Should Stay Up-To-Date

    By Caralyn Davis, Staff Writer - January 12, 2021

    Amid nationwide staffing shortages, veteran nurse assessment coordinators (NACs) often are being pulled to work the floor, and new NACs are coming on board with limited MDS training, notes Maureen McCarthy, RN, BS, RAC-MT, QCP-MT, DNS-MT, RAC-MTA, president/CEO of Celtic Consulting in Torrington, CT. “Resident care must come first for all staff, including NACs. However, as a result of that need to prioritize care delivery and wear more hats than ever, NACs face multiple stressors when it comes to completing the MDS and the Resident Assessment Instrument (RAI) process.”

     

    The Part A PPS Discharge assessment (i.e., the NPE item set) is an easy target for cutting corners in a time crunch, says McCarthy. “This assessment doesn’t directly impact payment under the Patient-Driven Payment Model (PDPM) in the Skilled Nursing Facility Prospective Payment System (SNF PPS) or under Medicaid case-mix systems. Nor is it used to meet OBRA regulatory requirements for assessment and care planning.”

     

    Consequently, discharge assessments—both the PPS Discharge assessment and the OBRA Discharge assessment—are often the first MDSs to be put aside “to do later” when NACs lack adequate time to complete assessments, adds McCarthy. “Payment assessments take precedence when the biller is standing over your shoulder asking, ‘Are you done yet?’” she explains. “In addition, NACs want to stay on schedule completing the OBRA assessment cycle of three Quarterly MDSs and one Admission/Annual assessment every 12 months.”

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  • jRAVEN 1.7.7 Free MDS Submission Software Updated (1/21)

    By QTSO - January 11, 2021

    The Resident Assessment Validation and Entry System (jRAVEN) was developed by the Centers for Medicare & Medicaid Services (CMS). jRAVEN is a free Java based software application which provides an option for facilities to collect and maintain MDS Assessment data for subsequent submission to the appropriate state and/or national data repository. jRAVEN displays the MDS Item Sets similar to the paper version of the forms. Please consult the jRAVEN Installation and User Guides for additional information.

    jRAVEN v1.7.7 is now available for download under the Downloads section at the bottom of this webpage. Users do not need a previous version of jRAVEN to download, install or use jRAVEN v1.7.7.

    jRAVEN v1.7.7 includes the following enhancements:

    • The new MDS VUT, v3.5.0, updated to support Issue #17 in Errata v3.00.6 and the new ICD Code files that are in effect as of 1/1/2021
    • The new PDPM Grouper, v1.0009, updated to include the ICD codes that are effective 01/01/202
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  • FY 2021 ICD-10 Code Lookup File for MDS Item I0020B (1/21)

    By CMS - January 11, 2021

    The lookup files containing the allowable ICD codes for item I0020B for FY2021 have been updated to contain the following ICD-10 codes , as well as remove M35.8:

    The new ICD-10 codes  may be used for assessments with target date on or after January 1, 2021: Z11.52, Z20.822, Z86.16, M35.81, M35.89 and J12.82. (Note that codes M35.81 and M35.89 replace code M35.8, which should no longer be used on assessments with target date on or after January 1, 2021.)

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  • FDA Alert: SARS-CoV-2 Viral Mutation Could Cause False Negatives on Tests, but Overall Risk Is Low (1/21)

    By FDA - January 11, 2021

    The U.S. Food and Drug Administration is alerting clinical laboratory staff and health care providers that the FDA is monitoring the potential impact of viral mutations, including an emerging variant from the United Kingdom known as the B.1.1.7 variant, on authorized SARS-CoV-2 molecular tests, and that false negative results can occur with any molecular test for the detection of SARS-CoV-2 if a mutation occurs in the part of the virus’s genome assessed by that test. The SARS-CoV-2 virus can mutate over time, like all viruses, resulting in genetic variation in the population of circulating viral strains, as seen with the B.1.1.7 variant. The FDA is taking additional actions to ensure authorized tests remain accurate by working with test developers and conducting ongoing data analysis to evaluate all currently authorized molecular tests. The FDA believes the risk that these mutations will impact overall testing accuracy is low.

    “The FDA will continue to monitor SARS-CoV-2 genetic viral variants to ensure authorized tests continue to provide accurate results for patients,” said FDA Commissioner Stephen M. Hahn, M.D. “While these efforts continue, we are working with authorized test developers and reviewing incoming data to ensure that health care providers and clinical staff can quickly and accurately diagnose patients infected with SARS-CoV-2, including those with emerging genetic variants. At this time, we believe the data suggests that the currently authorized COVID-19 vaccines may still be effective against this strain. The FDA will continue to keep health care providers and the public informed of any new information as it becomes available.”

    The FDA has been monitoring SARS-CoV-2 viral mutations, and potential impact on testing, throughout the pandemic. The presence of SARS-CoV-2 genetic variants in a patient sample can potentially change the performance of a SARS-CoV-2 test. Tests that rely on the detection of multiple regions of the genome may be less impacted by genetic variation in the SARS-CoV-2 genome than tests that rely on detection of only a single region.

    Three currently authorized molecular tests, MesaBiotech AcculaTaqPath COVID-19 Combo Kit, and Linea COVID-19 Assay Kit, may be impacted by genetic variants of SARS-CoV-2, but the impact does not appear to be significant. Importantly, the detection pattern that appears with the TaqPath and Linea diagnostic tests when certain genetic variants are present may help with early identification of new variants in patients to reduce further spread of infection. The recently identified B.1.1.7 variant has been associated with an increased risk of transmission, therefore early identification of this variant in patients may help reduce further spread of infection.

    The FDA has reminded clinical laboratory staff and health care providers about the risk of false negative results with all laboratory tests, including molecular tests. Laboratories should expect some false results to occur even when very accurate SARS-CoV-2 tests are used. Today’s announcement also provides important information and recommendations for clinical laboratory staff and health care providers who use molecular tests for the detection of SARS-CoV-2.

    The FDA will continue to communicate with the public as we have additional information to share. The FDA encourages stakeholders to report any adverse events or suspected adverse events experienced with molecular tests for detection of SARS-CoV-2. Voluntary reports can be submitted through MedWatch, the FDA Safety Information and Adverse Event Reporting program. Health care personnel and clinical laboratory staff employed by facilities that are performing COVID-19 testing should follow the reporting requirements for authorized laboratories as specified in the test’s Emergency Use Authorization. Prompt reporting of adverse events can help the FDA identify and better understand the risks associated with medical devices.

    ###



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  • FY 2021 PDPM ICD-10 Mappings (1/21)

    By CMS - January 11, 2021

    The Mappings file contains: 

    • Mapping of the ICD-10-CM Recorded in Item I0020B of the MDS Assessment to PDPM Clinical Categories 
    • Mapping of Comorbidities Included in the PDPM SLP Component to ICD-10-CM Codes
    • Mapping of Comorbidities Included in the PDPM NTA Component to ICD-10-CM Codes

    These are the codes added in the January 2021 update:

    Z11.52 — Encounter for screening for COVID-19

    Z20.822 — Contact with and (suspected) exposure to COVID-19

    Z86.16 — Personal history of COVID-19

    M35.81 — Multisystem inflammatory syndrome (MIS)

    M35.89 — Other specified systemic involvement of connective tissue

    J12.82 — Pneumonia due to coronavirus disease 2019

    (Note that codes M35.81 and M35.89 replace code M35.8, which should no longer be used on assessments with target date on or after January 1, 2021.)

    This is the seventh release (sixth production release, since 1.0005 was a beta release).

    This release also adds six ICD-10 codes that were inadvertently excluded from the NTA calculation in V1.0006:

    • T8484XA

    • T8389XA

    • T8321XA

    • T82399A

    • T82392A

     • T83021A 

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  • CMS Online Platform for Submissions of 1135 Waiver Requests and Inquiries (1/21)

    By CMS - January 10, 2021

    • New Web Platform for 1135 Waivers and Inquiries – The Centers for Medicare & Medicaid Services (CMS) is announcing a new web-based tool to assist Medicare/Medicaid-participating providers and suppliers in submission of 1135 Waiver requests and inquiries. With very limited exception, the new web system should be used for all 1135 waiver requests and/or PHE-related inquiries submitted on or after January 11, 2021.

    • Waiver requests related to Physician Self-Referral (Stark Law) should not be submitted via the new web portal. For these requests, please visit:https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Spotlightfor additional information.

    • This policy memorandum outlines the new changes to submission of 1135 Waiver requests/inquiries as well as resources available to providers and suppliers during the current COVID-19 Public Health Emergency (PHE) and future emergency events.

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  • CMS Proposes Healthcare-Associated Infection and Staff COVID-19 Vaccination Measures for SNF QRP UPDATED

    By CMS - January 08, 2021

    CMS has issued its 2020 measures under consideration (MUC) list. It includes two proposed SNF QRP QMs. The list includes more detailed info about proposed numerators, denominators, and rationales for each measure:

     MUC20- 0002: Skilled Nursing Facility Healthcare Associated Infections Requiring Hospitalization (outcome measure)

    This measure will estimate the risk-adjusted rate of healthcare-associated infections (HAIs) that are acquired during skilled nursing facility (SNF) care and result in hospitalizations. The measure is risk adjusted to “level the playing field” and to allow comparison of measure performance based on residents with similar characteristics between SNFs. It is important to recognize that HAIs in SNFs are not considered “never-events.” The goal of this risk-adjusted measure is to identify SNFs that have notably higher rates of HAIs that are acquired during SNF care and result in hospitalization, when compared to their peers

     

    More information:

    Draft Measure Specifications: Skilled Nursing Facility Healthcare-Associated Infections Requiring Hospitalizations For The Skilled Nursing Facility Quality Reporting Program


    MUC20- 0044: SARS-CoV-2 Vaccination Coverage among Healthcare Personnel (process measure)

    This measure tracks SARS-CoV-2 vaccination coverage among healthcare personnel (HCP) in IPPS hospitals, inpatient rehabilitation facilities (IRFs), long-term care hospitals (LTCHs), inpatient psychiatric facilities, ESRD facilities, ambulatory surgical centers, hospital outpatient departments, skilled nursing facilities, and PPS-exempt cancer hospitals.

    CMS press release:

    New Measures Under Consideration Mark a Milestone for CMS’s Reimagined Quality Strategy to Increase Digital Innovation and Reduce Burden

    Measures advance better quality care

    The Centers for Medicare & Medicaid Services (CMS) today unveiled its 2020 list of quality and efficiency measures under consideration. Quality measures are tools the agency uses to collect data from providers on the effectiveness, safety, efficiency, and timeliness of care beneficiaries receive. Every year, CMS evaluates all measures in its programs, proposing to remove those that have become less relevant and proposing new measures that may be more meaningful based on review by external health care experts. This year, almost all of the measures proposed would be collected digitally, meaning information comes from claims and other electronic sources, and would not require doctors to retrieve data manually. As a signal for CMS’s broader direction as the agency puts patients over paperwork in the push for quality and innovation, the 2020 list of measures under consideration represents “a first” on several important fronts, particularly where digital innovation and reducing administrative burden are concerned.

    Releasing the list is the first step in the “pre-rulemaking process,” when measures under consideration go to the National Quality Forum’s Measure Applications Partnership (MAP). Funded by CMS, the MAP is an independent, voluntary collaborative of organizations representing a broad group of stakeholders interested in or affected by the use of quality and efficiency measures and convened per statute to provide input on their selection. In a broader “CMS first,” a majority of measures under consideration in 2020 also rely on digital reporting of existing information, which can help providers spend more time with patients and less time collecting data. Coupled with a limited number of non-digital measures emphasizing patient-reported health outcomes, another priority for CMS, this digital innovation continues the reimagined quality strategy announced by CMS Administrator Seema Verma in 2017 as part of the Meaningful Measures initiative.

    “We launched Meaningful Measures because too many providers were wasting precious time and resources reporting on quality metrics, many of which were barely relevant to their specialty,” said CMS Administrator Verma. “Over the last four years, this initiative has delivered better, less onerous metrics that are actually useful to those who use them. The measures we are announcing today represent more of the same. They prioritize health outcomes, reduce burden, and give providers more time to do the work they entered medicine to do: treat patients.”

    Quality measures form the backbone of CMS’s ongoing effort to promote health for millions of Americans. The previously adopted measure for controlling high blood pressure, for example, helps CMS evaluate the quality of care by collecting data on the percentage of beneficiaries 18-85 years old whose high blood pressure has been adequately controlled during the measurement period, meaning their blood pressure readings were less than 140/90 mmHg. Additionally, reporting on these measures holds clinicians accountable for ensuring the best possible outcomes for beneficiaries.

    However, many quality measures have required intensive manual data collection and individual chart reviews, robbing doctors and other health professionals of valuable time spent caring for Americans. Over the last several years, CMS has been working to reduce provider burden by shifting toward measures that can be collected digitally using existing data. That strategy has the next iteration of the Meaningful Measures framework – or Meaningful Measures 2.0, the comprehensive initiative launched in 2017 to identify high-priority areas for quality measurement and improvement – at its heart.

    Though including a measure on the consideration list does not guarantee its adoption, the list represents a key first step and one built on collaboration between CMS and providers. Annually, the agency invites health care specialty societies and other stakeholder groups to submit candidate measures, due this year by June 30, narrowed down to identify promising candidates that warrant expert review as “measures under consideration.” The 2020 list – which includes a number of new measures, as well as several updates to modernize or replace existing measures – features:

    ·  Five outcome measures (measures that focus on the results of health care provided through Medicare), such as the rate of health care-associated infections requiring hospitalization for residents of skilled nursing facilities;

    ·  Five process measures (measures that emphasize efforts to promote standardized best practices), such as conducting kidney health evaluations or implementing interventions for patients with pre-diabetes (the medical term for blood glucose levels that are high but not yet high enough for a type-2 diabetes diagnosis). Importantly, the 2020 list includes three process measures for the coronavirus disease 2019 (COVID-19) vaccine. The measures under consideration list proposes looking at:

    ·  Vaccination coverage among health care personnel,

    ·  Vaccination by clinicians, and

    ·  Vaccination coverage for patients in End-Stage Renal Disease (ESRD) facilities;

    ·  Five cost/resource use measures (measures that evaluate how frequently health care items or services may be used, as well as how much they might cost) – including, for example, episode-based costs associated with addressing diabetes or asthma/chronic obstructive pulmonary disease;

    ·  Three composite measures (which summarize overall quality of care across multiple measures through the use of one value or piece of information); and

    ·  Two patient reported outcomes measures (measures where the information comes directly from the patient).

    All but three measures under consideration rely on digital rather than traditional “pen-and-paper” data collection. Of the non-digital measures, two are measures aimed at assessing COVID-19 vaccinations among health care personnel and patients in ESRD facilities, and the other reflects key patient-reported health outcomes, which help prioritize patient voices and empower patients to take an active role in their health.

    CMS expects to receive the MAP’s input on the 2020 measures under consideration by February 1, 2021. Experts at CMS and the Department of Health and Human Services will work collaboratively based on this assessment to select final measures available for further public comment through a notice of proposed rulemaking in the Federal Register.

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  • MDS 3.0 Provider User's Guide Updated, Including Validation Rpt Error Messages (1/21)

    By QTSO - January 08, 2021
    Key information about how to submit MDS files and how to obtain and understand error messages on initial and final validation reports. 
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  • MDS Validation Utility Tool (VUT) v3.5.0 (1/21)

    By CMS - January 08, 2021

    The Validation Utility Tool (VUT) is a software utility that can be used to validate MDS 3.0 submission files in XML format. The tool enforces the edits that are mapped to the MDS 3.0 items as published in the MDS 3.0 Data Specifications.

    The v3.5.0 VUT continues to support older data specification versions and has been updated to incorporate Issue 17 in Errata v3.00.6 to the current Data Specifications, as well as new ICD codes and is in effect on January 1, 2021. The MDS VUT version 3.5.0 is now available in the Downloads section at the bottom of this webpage.

    Please note that there are edits which the VUT cannot support because they are edits against existing ASAP system data. The VUT does not interface with ASAP therefore it cannot confirm those edits. The VUT does not currently interface with the RUG III and IV DLLs, or the new PDPM DLLs, therefore it does not recalculate and confirm that Grouper values are correct.

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