PASARR Exemptions and Resident Reviews
Jeannine LeCompte, Compliance Research Specialist
Once a would-be resident has received both Level I and Level II Preadmission Screening and Resident Review (PASARR) processes, and their treatment and placing have been designated, he or she can finally be admitted to a nursing facility, if that was the final determination.
There are three exemptions to this rule. The first is that individuals who have been discharged from a hospital into a Medicaid-certified nursing facility are exempt from PASARR if their stay is expected to last no more than 30 days. This is referred to as a “hospital discharge exemption.”
The second exemption applies to individuals who are being readmitted to a Medicaid-certified nursing facility after they had been transferred to a hospital and then sent back. In such cases, they can be readmitted using the original PASARR check.
The third exemption is for those residents being transferred from one Medicaid-certified nursing facility to another. In such cases, the original PASARR check may also be used. It is sometimes thought that “categorical determinants” are included under these exemptions. They are not.
Categorical determinations are those decisions based on an individual’s condition which meet one or more of seven key criteria: a serious illness, a terminal illness, provisional delirium, a provisional emergency, respite, a convalescent stay, and dementia. A nursing facility can omit the full Level II evaluation for individuals who meet one or more of these criteria only in circumstances where there is a limited amount of time, or when there is a clear need for urgent nursing facility care. However, in such cases, although the evaluation process is considerably shortened, the normal PASARR process still applies.
Provisional admissions are also permitted, with time limits, pending further assessments, when there is clearly a need for emergency protective services, as long as the stay period does not exceed seven days. A longer stay will require a Level II Resident Review. This Resident Review (RR) process is also mandated by law. It is designed to ensure that individuals are receiving appropriate treatment for their conditions, which may change over time. As a result, there must be a periodic review of the SMI/ID status of Medicaid-certified nursing facility residents.
An RR is triggered whenever an individual undergoes a significant change in status and that change has a material impact on their functioning as it relates to their SMI/ID status. The definition of a “significant change” is determined by a series of questions included in the Minimum Data Set (MDS).
The following are best practice guidelines for nursing facilities when dealing with PASARR admissions. Ensure that:
- The facility has policies and procedures that clearly outline a systematic process for the PASARR program
- Appropriate staff are trained and knowledgeable regarding when a Level I or Level II PASARR is required
- The facility has a tracking system to monitor if a resident’s hospital discharge exemption exceeds 30 days
- Appropriate staff are educated on what to do when a resident’s status changes
- Appropriate staff are educated on how to develop a baseline care plan/person-centered care plan for a resident with a Level II PASARR
Not following your state’s PASARR process may be perceived by regulators and other state and federal agencies as fraud, waste, or abuse of government funds paid to the facility for provision of quality care.
