I recently had the opportunity to tour three WWII-era ships, the USS Yorktown (CV-10), the USS Laffey (DD-724) and the USS Wisconsin (BB-64). All three provided me with extraordinary experiences.           

I’ve seen these kinds of ships in movies and old news reels but the actual encounter was something I’ll never forget. I was astonished at the engineering complexity. I marveled at the size and power of the armaments and the vast maze that awaited me as I explored the decks that were open to the public. 

Experiencing these ships has me thinking about the complex nature of our industry. As we have been helping our customers prepare for the MDS changes that are coming this October and next, I hope your interdisciplinary team has been having some conversations about these as well.

Let’s take a quick tour of the upcoming revisions. Some are cosmetic, and some are more substantial.

Peeking below the decks

First, there have been no fewer than 43 specific revisions to the MDS data set(s) that will take place on October 1. Many of these are completion guidance related and affect multiple data set variations. In the MDS 3.0 downloads there is an item set revision history document that will help orient you to these revisions.

The final version MDS 3.0 v1.19.1, which contains these revisions, was posted to the MDS 3.0 website a few months ago. You will need to spend some time orienting yourself to the two new MDS items that have been added as well. 

Item N0415K1 – Anticonvulsant, has been added to section N along with coding instructions on page N-8 of the revised RAI Manual.

Item O0350 – Resident’s COVID-19 vaccination is up to date, has been added to section O along with coding guidance on pages O-19 and O-20.

The final change to the data set is the removal of section GG1030 and GG0170 admission column 1, Discharge Goals. These items were needed to calculate a SNF QRP quality measure that has been retired and so these items are no longer necessary. 

Checking out the RAI paint

Did you know that warships, like the ones I visited recently, are painted that drab gray color for a reason? It helps to camouflage the ship in different weather conditions and makes the vessel harder for the enemy to spot when out at sea.

Likewise, the RAI manual is the skin color of the MDS , and when applied correctly, helps the MDS stay under the radar with accurate completion.

This fall, there have been several revisions to version 1.19.1 of the recently posted RAI Manual as well. As already noted, there is now guidance related to the two new items, and guidance has been removed related to the one removed item.

In addition, revisions have been made to the manual instructions in Chapter 3, sections A, C, H, I, K, N, O, X, Chapter 5, and Appendix A, B, C and F. 

Furthermore, the Centers for Medicare & Medicaid Services has posted a separate document titled, “MDS 3.0 RAI User’s Manual (v1.19.1R) Hyperlink Update Supplement v1 Effective October 01, 2024.” 

The purpose of this document is that due to external web page changes, hyperlinks (links) may occasionally redirect, become unreachable, or the information provided on the webpage may change. It serves as a supplementary list of links in the MDS 3.0 RAI User’s Manual version (v)1.19.1 that require updates as identified throughout the lifetime of the document. RAI manual replacement pages can be found following the list. 

The future is built on the past

Change continues as one constant we can count on. The ships that protect our waters today are much bigger and vastly more complex than the antiques I visited. While in Norfolk, VA, recently, I watched as new ships were being built. They are impressive and intimidating.

As we move into the next few years, the MDS will continue to change to accommodate the expanding SNF VBP and QRP programs with added complexity. Specifically, CMS has already finalized an update for Oct. 1, 2025, related to the SNF QRP.

The following four new items and one revised item will be added to the MDS next year in CMS’ ongoing effort to create an awareness of and engagement with social determinants of health and Social Risk Factors that are present in our resident populations.

  1. A Living Situation item to address housing insecurity
  2. Two Food item questions that will address food insecurity
  3. A Utility item that will address utilities insecurity
  4. The Transportation item, which has been simplified and revised to define a standard lookback

These items will be collected only at admission and will exclude any SNF residents who, immediately prior to their hospitalization that preceded a new SNF stay, resided in a NF for at least 366 continuous days.

On a positive note, next year CMS also will be removing all O0400 A, B, C and E Therapies items from the five-day Medicare required assessment beginning Oct. 1, 2025. These items have not been necessary for calculating a HIPPS code since PDPM began in 2019. 

Because of this change, CMS will need to make revisions to the covariate criteria for the discharge function score measure. Former exclusion number five for this quality measure, “The resident did not receive physical or occupational therapy services at the time of admission (i.e., on the 5- Day PPS assessment),” has been moved to the covariate section on v6.0 of the Skilled Nursing Facility Quality Reporting Program Measure Calculations and Reporting User’s Manual. 

A growing sense of RAI responsibility

Seeing the sights, inhaling the smells, touching the walls, and walking through the cramped quarters of these ships, I got a small taste of what it might have been like to live on one of these ships as it sailed the seas protecting our freedoms. 

I am patriotic to the core, and walking the decks of these ships, I could not have been prouder of the men and women who served our country within the hallowed corridors and feel a sense of responsibility to pass their legacy on in any way that I can.

I’m also consistently amazed at how complex and demanding the RAI process is and the dedication it takes to complete day in and day out, and I am increasingly aware how the design of this tool is intended to positively impact those for whom we care.

As we navigate the RAI-related changes that are headed our way in the next few years, our goal should be to consider the impact our engagement with these revisions has on the lives of the residents we serve. 

The RAI process is an adventure the IDT can enjoy together.  Its destination? The reason we all got into this profession. I hope you feel that as deeply as I do. 

Anchors aweigh!

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation. For further inquiries, he may be contacted here.

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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