Quality-focused clinicians and long-term care operators have long recognized the important role that effective data collection and analysis plays in resident care, satisfaction and positive outcomes. Now that the Minimum Data Set 3.0 is in full swing, it’s also becoming increasingly apparent that good data also is essential for ensuring regulatory compliance and accurate coding and reimbursement.
While the MDS process always has encouraged data collection, it was the transition to the new resident assessment tool that really moved effective data use to the forefront.
“The change to MDS 3.0 reinforced these principles and added validation [with] the emphasis on the resident interview process,” noted Marie Infante, senior vice president, chief compliance officer and general counsel for healthcare for Golden Living, Washington.
“These changes should help facility staff use the resident-specific data in a more meaningful way,” she added.
Still, as many long-term care providers have discovered, collecting and analyzing data thoroughly and accurately isn’t always easy, particularly in light of time and resource constraints that have, in many cases, become even more magnified since the more laborious MDS 3.0 took effect last October.
“MDS 3.0 has brought back the focus on quality care. The more information that’s gathered with MDS 3.0, the better that is for care planning and addressing residents’ needs. If you’re not using that data properly, though, it also opens up the door for compliance issues, survey problems and other areas of liability,” stressed Monica Pappas, vice president of clinical reimbursement for Encore Healthcare LLC.
“Good clinical decisions and accurate MDS submissions require good data auditing. But with the volume of information being collected, I just don’t know how facilities can do that all on their own,” Pappas continued. “It’s just too labor-intensive and there’s a greater risk for error.”
Shedding light on data quality
For a growing number of facilities, the answer to their data collection and analysis dilemmas has come in the way of comprehensive data integrity audit programs.
“It’s very important for us to be able to audit our MDS assessments for compliance purposes, and make sure that those MDSs are submitted on time,” said Stephanie Papoulis, corporate counsel for Senior Care Group.
At the recommendation of its insurance company, the Tampa, FL-based skilled nursing provider chose PointRight for its data integrity solutions.
“Through PointRight, we have a seamless interface that analyzes every MDS assessment and lets us know, on a daily basis, exactly how many MDS assessments have been submitted for each of our properties. That auditing component is important because our MDS coordinators are very busy with resident interviews and other hands-on [aspects] of MDS 3.0, and they can sometimes miss something.”
With the application of 3,500 coding checks, 750 Centers for Medicare & Medicaid Services’ consistency checks and more than 300 clinical statistical tests, the PointRight Data Integrity Audit screens each MDS assessment in much the same way recovery audit contractors and surveyors do to help ensure that a clean record is submitted. DIA checks for logical and clinical consistency, relationships between symptoms and diseases, relationships between treatments and disabilities, and overall coding of MDS. Instant feedback is then provided on potential inconsistencies and MDS assessment documentation requirements, which further helps facilities ensure accurate reimbursement, maintain regulatory compliance and improve resident care.
One MDS area where good data collection is especially critical is Activities of Daily Living compliance. That’s because the MDS 3.0 methodology scores residents lower than the MDS 2.0 system, explained senior housing and healthcare consultant Patricia Boyer, MSM, RN, NHA, of Boyer & Associates LLC. “With that issue and the Rule of Three algorithm, ADL documentation is critical,” added Boyer, who also authors a monthly “Ask the Payment Expert” column for McKnight’s Long-Term Care News. “We are seeing lower ADLs due to these issues. Accuracy of this data is critical to get appropriate reimbursement. Providers need to be able to capture the highest level of need possible.”
Maintaining access to critical data during the MDS 3.0 migration blackout period also has led senior living providers to seek out data integrity solutions. In Encore Healthcare’s case, the organization began partnering with PointRight and relying on the Data Integrity Audit program even before the start of MDS 2.0.
“We knew that somewhere down the line, we would be in the dark with quality measures. At the same time, we knew that CMS would not be in the dark,” said Pappas, referring to the period of time during the migration to MDS 3.0 where CMS pulled reports offline to aggregate data and define how to measure for the quality measures under the new assessment tool. “We decided that if we were going to be submitting all this data to CMS, we would be in big trouble if we weren’t auditing it first.”
Auditing aides’ education
For Pappas, one of the most satisfying, if not surprising, benefits of the DIA program has been its role in education. Over the past few months, she’s pored over data received from PointRight to track trends and potential problems, and pinpoint opportunities for education.
“What the data can tell you is fascinating. I’ve been able to look at wound-related data, for example, identify trends and know, without anyone even telling me that there’s been a staffing change,” said Pappas. “What’s great about good data collection and analysis is I can then use that as an educational opportunity.”
The system promotes better interdisciplinary involvement and staff accountability. Per Encore’s policy, as soon as MDS staff submits the MDS to PointRight and then receives feedback on the assessments, the MDS staff must then take that information directly to where an issue or conflict originated. From there, the issue is brought to the attention of the multidisciplinary team. They then have 24 hours to research the alert or issue and determine the course of corrective action.
“The DIA is also helping us make sure we have the right documentation to support what’s coded. Even if a therapy or service was provided and [warranted], you have to have the documentation to back that up.”
Further, Pappas pointed out, the DIA serves as “another set of eyes, which not only makes MDS coordinators’ lives easier, but also makes them – and other staff – more conscientious about data collection and assessments.
Using MDS data, audits and analysis to boost staff awareness, proactive decision-making and facility-wide training is an approach that Infante also wholly supports.
“There is no substitute for staff training and coaching through the MDS data collection process,” she stressed. “People generally have to have a high degree of confidence in data before they will rely on it to make decisions,” she said.
“So training, consistency, and close attention to the procedural changes of MDS 3.0 are all important elements of an effective MDS compliance program.”
