The Centers for Medicare and Medicaid Services' (CMS) Minimum Data Set, version 3 (MDS 3.0) issues have finally been resolved, but two new Resource Utilization Group, version 4 (RUG-IV) errors have been discovered.  Please share this update with your MDS coordinators.

MDS 3.0 Submissions Issues
The processing of MDS 3.0 submission files in the Assessment Submission and Processing (ASAP) System was “fixed” and restarted earlier this week.  Click here to read the memo from the Quality Improvement and Evaluation System (QIES) support office to QIES state coordinators, dated October 12, 2010.  Attached to the report are three additional documents:

1. The first attachment to the memo contains a list of the MDS 3.0 submission files that were reprocessed on 10/11/10.

2. The second attachment to the memo contains a list of MDS 3.0 accepted assessments that were reprocessed on 10/11/2010.  The nursing home records were included in a state assessment extract file.  Since these records have been reprocessed and information on the record may have changed, users of the state assessment extract file will need to delete the nursing home assessments listed in the attachment from their system and use the reprocessed records instead.

3. The third attachment to the memo contains a list of MDS 3.0 assessments that were rejected and reprocessed.  These records were rejected due to edit failure, not well-formed XML file, or inability to determine the provider of the record.  Due to the revisions to the RUG logic, some assessments that were rejected originally due to edit failure may be accepted during reprocessing.

Facilities should be able to obtain their validation reports via their Certification and Survey Provider Enhanced Reports (CASPER) files.  Any nursing home assessments that were accepted during reprocessing will be in the State Assessment Extract file dated 10/12/2010.

RUG-IV Grouper Issues
CMS also reports that two errors have been discovered in the RUG-IV Version 1.00.8 specifications and DLL.

Error #1
When a Start of Therapy Other Medicare Required Assessment (OMRA) does not produce a RUG-IV Rehabilitation Plus Extensive group or a Rehabilitation group, the RUG-IV Version 1.00.8 grouper returns a Start of Therapy OMRA error code and returns a default (AAA) classification.

The error code and default classification are returned for both RUG-IV Medicare classification (MDS Item Z0100A) and RUG-IV Medicaid classification (MDS Items Z0200A and Z0250A), but should have been limited to Medicare classification only.  For Medicaid classification, a non-default classification should result, and no error code should be returned.  In states that require submission of RUG-IV Medicaid classification, the CMS ASAP system will have stored an inappropriate default classification caused by this error.

RUG Version 1.00.8 specifications for facility software are that a record that receives a Start of Therapy OMRA error code from the RUG-IV grouper is an invalid record, and the facility software may not allow that record to be submitted.  Within facility software using version 1.00.8, a valid Start of Therapy OMRA may be barred from submission because it produces a RUG-IV Medicaid classification in a group other than Rehabilitation Plus Extensive or Rehabilitation.

Error #2
Version 1.00.8 provides a non-default RUG-IV Medicaid classification on a Start of Therapy OMRA, not combined with an OBRA or other prospective payment system (PPS) assessment.  This is inappropriate because the only RUG-IV items on such a Start of Therapy OMRA are limited to rehabilitation and extensive services items.  Without the other RUG-IV items, the only classifications possible are Rehabilitation Plus Extensive, Rehabilitation, and Reduced Physical Function.  For a Start of Therapy OMRA not combined with an OBRA or other PPS assessment, the RUG-IV Medicaid classification should be the default (AAA).

This problem does not occur for RUG-III Medicaid classification.  RUG-III correctly returns a default classification (BC1) for these Start of Therapy OMRAs.  The problem will only occur in RUG-IV Medicaid classification.

New RUG-IV Version
A new RUG-IV Version 1.00.9 grouper package is under preparation, and will be posted on the CMS MDS 3.0 Technical information by October 14, 2010.  The ASAP submission system was upgraded to Version 1.00.9 before performing the reprocessing described above.

Note:  Facility software using RUG-IV Version 1.00.8 may not allow submission of Start of Therapy OMRA assessments with a Medicaid classification other than Rehabilitation Plus Extensive or Rehabilitation.  Once the facility software is upgraded to RUG-IV Version 1.00.9, RUG-IV should be recalculated for these records and they can then be submitted.

Doug Beardsley
952.851.2489
dbeardsl@careproviders.org

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