Completing the Minimum Data Set (MDS) 3.0 Questions for Medication Regimen Review

Jeannine LeCompte, Compliance Research Specialist

The Minimum Data Set (MDS) 3.0 is a critical part of the Resident Assessment Instrument (RAI), which forms the foundation of a comprehensive assessment for all residents of Skilled Nursing Facilities certified to participate in Medicare or Medicaid.

MDS 3.0 consists of a core set of screening, clinical, and functional status elements, including common definitions and coding categories, and has been designed to improve the reliability, accuracy, and usefulness of the process—and to include the resident in the assessment.

The items which feature in the MDS questionnaire standardize communication about resident problems and conditions within nursing homes, between nursing homes, and between nursing homes and outside agencies.

The required subsets of data items for each MDS assessment and tracking document (e.g., Comprehensive, Quarterly, Federal Omnibus Budget Reconciliation Act Assessment Discharge, Entry Tracking, Prospective Payment System (PPS) item sets) reflect the acuity level of the resident, including diagnoses, treatments, and an evaluation of the resident’s functional status.

The MDS also classifies Medicare residents into Resource Utilization Groups (RUGs). The RUG classification system is used in PPS for skilled nursing facilities, non-critical access hospital swing bed programs, and in many state Medicaid case mix payment systems to group residents into similar resource usage categories for the purposes of reimbursement.

MDS assessment data are also used to monitor the quality of care in nursing homes. MDS-based quality measures (QMs) were developed by researchers to assist:

(1) State survey and certification staff in identifying potential care problems in a nursing home;

(2) Nursing home providers with quality improvement activities/efforts;

(3) Nursing home consumers in understanding the quality of care provided by a nursing home; and

(4) CMS with long-term quality monitoring and program planning.

The MDS 3.0 activity report lists the accepted assessments, tracking records, and inactivation requests that were submitted by, or on behalf of, a facility during a specified time frame—i.e., the period of care from admission to discharge.

This data must be completed within fourteen days of admission and submitted electronically to CMS.

Data which must be captured includes, but is not limited to, resident internal ID, social security number, resident name, Medicare number, date of birth, gender, Federal Omnibus Budget Reconciliation Act assessment, PPS assessments, entry/discharge reporting, type of discharge, and of course, the Calculated Medicare (MCR)/Medicaid (MCD) RUG.

All data has to be entered in digital (number) format, except for the “dash” or (-), which indicates the item was not assessed or, in the case of a few items, that the event did not occur.

There should be no confusion over the use of a dash, as it is now allowed for almost all MDS 3.0 items but is recommended to be used minimally.

According to instruction in the RAI User’s Manual, the Medication Regimen Review (MRR) should be completed for new residents upon admission, or as close to start of the SNF PPS stay as possible. The MDS 3.0 version 1.16.1 effective October 1, 2018, includes three questions that relate to the process of the MRR. They are:

N2001: Did a complete drug regimen review identify potential clinically significant medication issues?
N2003: Did the facility contact a physician (or physician-designee) by midnight of the next calendar day and complete prescribed/recommended actions in response to the identified potential clinically significant medication issues?
N2005: Did the facility contact and complete physician (or physician-designee) prescribed/recommended actions by midnight of the next calendar day each time potential clinically significant medication issues were identified since the admission?

Timely and thorough completion of the MRR process and accurate coding of the MDS questions about MRR are important components of quality care and fraud, waste, and abuse prevention. As significant medication issues are identified and addressed, residents are protected from medications they no longer need or that are not appropriate for them, and facilities avoid submitting claims for medications that residents should not use, thus preventing fraudulent and/or wasteful billing for inappropriate medications for residents.