CMS Issues S&C Memo: MDS 3.0 Discharge Assessments

The Centers for Medicare and Medicaid Services (CMS) issued a Survey and Certification (S&C) memo to State Agency Directors on August 23, 2013 outlining steps nursing home providers must take to address any MDS 3.0 discharge assessments that have not been completed and/or submitted since the inception of MDS 3.0. These missed discharges have resulted in residents who are no longer active appearing on the facility’s current MDS 3.0 Roster report. The memo clarifies steps to take to address completion of discharge assessments for inactive residents by September 30, 2013 to ensure compliance with regulation.  

Beginning October 1, 2013, MDS assessments older than three years will no longer be accepted.  Since the discharge assessment information is used for quality measurement (QM) and to minimize impact on QM data, CMS has selected a reference date of October 1, 2012.  CMS requires providers to take the following steps when discharge assessments have not been completed and/or submitted prior to September 30, 2013:

  1. Identify any residents appearing on the facility’s current MDS 3.0 Roster report who are no longer active residents.
  2. If the resident was discharged prior to October 1, 2012, a discharge assessment must be completed for the resident indicating the actual date of discharge in Item A2000, Discharge Date.
  3. If the resident was discharged on or after October 1, 2012, a discharge assessment must be completed for the resident indicating the actual date of discharge in Item A2000, Discharge Date.

For more details related to completing and submitting the discharge assessments for inactive residents, members should review the entire S&C Memo.  Cil Bullard, RN, CPC, Virginia RAI/OASIS Coordinator, has communicated information regarding the CMS directive to MDS Coordinators across the state in a broadcast email.  She has offered to schedule a conference via telephone to provide assistance with reviewing the missing discharge assessments. To schedule a teleconference, MDS Coordinators should contact her via email.