Preadmission Assessment and Resident Review: Getting it Right
Jeannine LeCompte, Compliance Research Specialist
Medicaid-certified nursing facilities, regardless of payer source, must have a Preadmission Screening and Resident Review process in place. This is due to the Omnibus Budget Reconciliation Act (OBRA), and failure to comply can constitute a fraud, waste, and abuse determination by the Centers for Medicare and Medicaid Services (CMS). CMS, in its State Operations Manual Appendix PP, designates this program as “PASARR,” while the Minimum Data Set (MDS) uses the abbreviation “PASRR.”
PASARR is a federal requirement designed to ensure that individuals with mental disorders/mental illness (MD/MI) or intellectual disabilities (ID) are not inappropriately placed in Medicaid-certified nursing homes. The purpose of serious mental illness (SMI) or intellectual disabilities (ID) screening is twofold: first, it ensures that all applicants are offered the most appropriate setting for their needs (in the community, a nursing facility, or acute care setting), and second, to ensure resident safety.
PASARR is an important tool for states to use in rebalancing services away from institutions and toward supporting people in their homes, and also to comply with the United States Supreme Court decision, Olmstead vs L.C. (1999). The Olmstead decision ruled that under the Americans with Disabilities Act (ADA), individuals with mental disabilities have the right to live in the community rather than in institutions if, “the State’s treatment professionals have determined that community placement is appropriate, the transfer from institutional care to a less restrictive setting is not opposed by the affected individual, and the placement can be reasonably accommodated, taking into account the resources available to the State and the needs of others with mental disabilities.”
PASARR is also designed to promote person-centered care planning by ensuring that psychological, psychiatric, and functional needs are considered along with personal goals and preferences in planning long-term care.
The regulations governing PASARR are found in the Code of Federal Regulations, primarily at 42 CFR 483.100-138, Subpart C, “Preadmission Screening and Annual Review of Mentally Ill and Mentally Retarded Individuals.”
According to these regulations, an individual is considered to have an SMI or MI if they have a major mental disorder diagnosable under the Diagnostic and Statistical Manual of Mental Disorders, 3rd edition, revised in 1987. These SMI disorders include a schizophrenic, mood, paranoid, panic, or other severe anxiety disorder; somatoform disorder; personality disorder; other psychotic disorder; or another mental disorder that may lead to a chronic disability.
It is important to know that a primary diagnosis of dementia, including Alzheimer’s disease or a related disorder, is generally not included in this definition.