OHCA has recently learned that a number of member facilities have received a case mix penalty letter related to their annual case mix score calculation because of errors in their records at the end of the first quarter of the year, March 31, 2009. The letter cites language in OAC 5101:3-3-43.3 that allows the agency to reduce the quarterly facility average total case mix score five percent less than the quarterly facility average total case mix score from the preceding calendar quarter. ODJFS has explained that when a facility has an assigned or a penalty score that score is not used to calculate the provider's annual facility average case mix score. Rather, instead of averaging four quarterly scores, three quarterly scores will be averaged when there is an assigned and/or penalty score i! mposed (the penalty score will be dropped from the calculation). On the other hand, a penalty or assigned score can be used to calculate a semiannual case mix score. which is the score use to determine direct care rate setting. The annual case mix score is used for calculating one of quality incentive points, whether a facility’s is above the statewide average
In the ODJFS letter, reasons for the penalty are noted as failure to submit appropriate modifications or discharge tracking records by the eightieth day after the reporting period end date. The most frequently reported problems reported historically by ODJFS are facility end of quarter assessment records exceeding their certified capacity, and Social Security Number errors.
ODJFS officials explain that currently there is no appeal process for case mix score penalties as a result of NF submission errors. They explain that skilled nursing facilities are given several opportunities to correct submission errors (weekly reports, two preliminary case mix score reports). Also, as a courtesy, the MDS Help Desk calls facilities with submission errors each time a preliminary report is posted.
A facility’s case mix score is still one part of their reimbursement that a facility can manage and impact, so preventing reductions and penalties should be of a very high priority. In addition to the reports and courtesy calls from ODJFS, there are a variety of MDS Key Reports that can be useful tools for facilities in developing systems to prevent or correct data problems before they even get to the quarter end preliminary reports. One such report is the Roster Report, that lists all residents currently in the system and their last assessment date. At a minimum, facilities need to have a routine system to effectively review and correct problems found on the series of two preliminary scores provided though the submission system. That needs to include comparing all resident assessment reports listed on the preliminary reports with the facility’s census at the end of the ! quarter. If assessments are found in the quarter end batch that were not in the facility census, either actually, or on a bed hold, the facility needs to complete appropriate discharge tracking forms. The problem related to Social Security Number is generally that an individual resident can end up with multiple records as if they were more than one person. When this is found, it is necessary to correct the SSN in all of the resident’s assessment files, even the historical records. The duplicate resident report may assist in finding this type of error.
OHCA has posted the MDS Key Report on the Clinical & Operational page of the Association website under MDS: MDS Key Reports - Revised 10.01.06. This also includes an explanation and example of the preliminary reports that come out of the system and how they must be rectified with the reporting period end date census.
Many of the reports that are available from the MDS system are helpful tools, including validation reports of actual submissions that facilities are advised to keep on file as evidence of successful submissions. They may also be used as gauges of a facility’s MDS process and areas that may need improvement.
OHCA is developing a webinar on this topic that will go into more detail about the importance of these reports.
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