Texas MDS staff have revised and reposted the MDS Notification ”Minimum Data Set (MDS) 3.0 Inactivation Procedure Clarification

Minimum Data Set (MDS) 3.0 Inactivation Procedure Clarification - Revised

The Centers for Medicare & Medicaid Services (CMS) has clarified the MDS 3.0 inactivation procedure to be used for MDS 3.0 Omnibus Budget Reconciliation Act (OBRA) and Prospective Payment System (PPS) records. An inactivation can only be completed after MDS 3.0 records have been accepted into the Quality Improvement Evaluation System (QIES) Assessment Submission and Processing (ASAP) system.

The MDS 3.0 Resident Assessment Instrument (RAI) Manual, page 5-12, offers the following information:

• An Inactivation (Item X0100 = 3) must be completed when any of the following items are inaccurate: Type of Provider (Item A0200), Type of Assessment (A0310), Entry Date (Item A1600) on an Entry tracking record, Discharge Date (Item A2000) on a Discharge/Death in Facility record, or Assessment Reference Date (A2300) on an OBRA or PPS assessment.
• When inactivating a record, the provider is required to submit an electronic Inactivation Request record. This record is an MDS record but only the Section X items are completed. This is sufficient information to locate the record in the QIES ASAP system, inactivate the record and document the reason for inactivation.
• For instances when the provider determines that an event date (ARD, entry date, and discharge date) or type of assessment item (A0310) is incorrect, the provider must inactivate the record in the QIES ASAP system, then complete and submit a new MDS 3.0 record with the correct event date or type of assessment, ensuring that the clinical information is accurate.

CMS Clarification: CMS staff clarified bullet number three 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 Entry or Death in Facility record:

• Facility staff must complete a new record with the correct event date or type of assessment, and
• Enter new completion dates in Section Z.

If the MDS 3.0 record is an assessment:

• Facility staff must set a new Assessment Reference Date (ARD) on a paper copy of the MDS Item Set or in the facility MDS software,
• Complete a new MDS assessment, coding all MDS items based on the new ARD and the appropriate look-back period, and
• Enter new completion dates in Section V (if active on that item set) and in Section Z.

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.

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. Whether or not the facility inactivates the resent version of an inactivated MDS and completes a new MDS record to satisfy the CMS clarification is a determination made by facility management staff.