This page addresses issues related to MDS corrections, modifications and inactivations.
It is the responsibility of MDS coordinators and other MDS personnel to read, understand, and implement the correction policy described in the RAI Manual, Chapter 5. Please contact the state MDS Automation or RAI Coordinator if you have any questions about what you have read. Below is a list of issues that nursing facilities encounter when correcting assessments and how to address them.
Edit: To change MDS item values without completing Section X
Modify: To complete Section X and change MDS item values in other sections
Correct with a modification: Refer to definition of Modify
How far back can facilities go to make corrections?
Currently, facilities can make corrections to MDS 3.0 records up to 36 months (3 years) back. Missing tracking records should be submitted up to 36 months back if they are discovered. The only exception to this is that Entry tracking records for entries that occurred between October and November of 2010, but were not submitted, do not have to be submitted now (according to CMS). However, all Entry tracking records for entry dates on or after December 2010 must be submitted.
When must items be edited instead of corrected?
All items in an MDS record that is not accepted into the CMS system can be edited. In other words, an MDS record that has not been submitted, or that was submitted and rejected, must be edited — it cannot be modified or inactivated.
Which items must be corrected with a special form?
The Facility ID (FAC_ID) and item A0410 must be corrected using a special form that can be requested from the state MDS Automation Coordinator. An MDS record must be accepted into the CMS system before it can be corrected using the special form. Test records that need to be deleted from the CMS system after being accepted require the special form, as well.
Inactivations: When and how do facilities correct MDS records with an inactivation?
Inactivations negatively impact facilities due to the personnel time required for the correction and the possible need to bill at the default rate or no rate at all. First read about how inactivations must be correctly completed, then read how to avoid the need for inactivations.
The MDS 3.0 Resident Assessment Instrument (RAI) Manual, page 5-12, gives the following information:
CMS Clarification: CMS staff clarified the information in the fourth bullet to ensure that all facility staff understand that when an MDS is inactivated, the facility must complete and submit an entirely new MDS 3.0 record (X0100=1 Add New Record) with a correct event date or type of assessment. This is true whether the record is an assessment or an Entry or Death in Facility record.
If the MDS 3.0 record is an assessment:
If the MDS 3.0 record is an Entry or Death in Facility record:
Inactivation of assessments used for Medicare or Medicaid payment, and completion of new assessments, may result in payment consequences. If the resident has been discharged and is no longer in the facility, records with an MDS assessment type listed in A0310A cannot have an ARD set after the date of discharge. If the resident has been discharged from Medicare Part A, whether the resident remains in the facility or not, records with an MDS assessment type listed in A0310B and A0310C cannot have an ARD set after the date of Medicare discharge. Without an ARD set on or before the day of discharge, these OBRA and PPS assessments may not be completed or submitted.
To avoid the negative impacts of inactivations (additional staff time and possible financial loss), DADS MDS staff recommend a quality double-check on every MDS record of the items that would cause an inactivation. It is recommended that a second person (other than the person who originally entered the data) who is familiar with MDS scheduling perform the quality double-check.
There may be instances when a facility has already inactivated an MDS record and resent an edited version of the record instead of completing a new MDS record. Such edited versions of the record are invalid and should be inactivated, as well.
How would a facility correct an MDS record that has a correct reason for assessment combined with an incorrect reason for assessment?
Any time the Reason for Assessment, or any other MDS item, is incorrect, the MDS must be corrected. The invalid MDS would be inactivated and a new MDS assessment would be completed with the correct reason for assessment. A new Medicare assessment could be completed with a new ARD if the resident has not been discharged from Medicare before the ARD. A new OBRA assessment could be completed with a new ARD if the resident has not been discharged from the facility before the ARD.
For example, what must be done when a facility submits a combined Admission/14-day assessment and then realizes that the resident was discharged from Medicare before the Assessment Reference Date (ARD) of the assessment?
In this case, the Admission/14-day assessment must be inactivated and the Admission assessment would have to be redone with a new ARD per the inactivation policy. If the resident is no longer in the facility due to death or discharge, a new Admission assessment could not be submitted for that resident and the facility would have to accept a missed assessment status for the Admission assessment.
Other common examples of invalid combinations include:
Be mindful of the difference between MDS with incorrect reasons for assessment that are invalid and MDS that are done early or late but are valid. For example, a valid COT with an ARD set one day early is not optimal but it should not be inactivated. Conversely, a COT with an ARD set after a resident was discharged from therapy is invalid and must be inactivated.
What must be done when an MDS record has a correct reason for assessment combined with an undesired optional Change of Therapy?
The facility must decide whether or not to inactivate and correct the MDS.
For example, if a combined 30-day/COT was submitted and the COT caused a lower RUG, the facility could not inactivate the assessment without adverse consequences. Inactivating the assessment would mean the 30-day would have to be redone with an ARD no earlier than the date of correction, the COT would be due on the original ARD but would also have to be redone with an ARD no earlier than the date of correction (and probably combined with the new 30-day). That means the 30-day and COT would both be late assessments and payment would be even more negatively affected than the original combined assessment. Thus, facility MDS personnel need to carefully consider the consequences before inactivating an assessment.
If MDS personnel determine NOT to inactivate the MDS, the combined MDS must be utilized for billing as outlined in the MDS 3.0 RAI Manual and billing regulations. Facility staff may NOT change the Assessment Indicator (AI) for a Resource Utilization Group (RUG) when billing. Even though the COT is optional, the facility must still bill Medicare based on the RUG resulting from the optional COT.
Tip: Double-check your MDS before submitting.
What dates do I change when correcting an MDS?
Does the current MDS staff really have to correct old assessments that were done by someone else?
Did you get a validation report error -3745 "No match found"?
Did you get a validation report error -3783 "Inconsistent X0800"?
Contact your software vendor if you need help with any of these steps.
Did you get a validation report error -1007 "Duplicate Assessment"?
Updated: February 21, 2013