Q26. How does DMAS define a late assessment?
A26. If the Omnibus Budget Reconciliation Act (OBRA) quarterly assessment is not scheduled within the timelines as defined by the requirements in the Resident Assessment Instrument (RAI) manual published by CMS, the assessment shall be considered late. The nursing facility shall bill the default RUG code until a new assessment has been completed and accepted.
Assessments with Assessment Reference Dates (ARD) that do not comply with OBRA scheduling requirements are subject to default. For example, a quarterly assessment is required to have an ARD no more than 92 days after the most recent OBRA assessment’s ARD. If the provider does not open this assessment until after the last required date, then the provider will need to bill the default rate from 92 days after the most recent OBRA assessment until the next OBRA assessment’s ARD. All OBRA scheduling requirements as listed in the RAI manual apply.
Comment: Notice, you get default for the number of days that ARD is out of compliance, not for late completion or late transmission. If you have late OBRAs now that will be used to pay in November, it would be wise to set a new one now so the latest one won't be late.
I also notice they do not use the definition of "Late ARD" for a comprehensive that is more than 366 days from the ARD of the last comprehensive. They only use the 92 day timeframe.
Additionally there are some troublesome issues in this Q&A. For example, it alludes to "opening" the assessment, but they seem to mean "setting the ARD." I don't think they have finished refining this yet. It is prudent to strive for timely ARD, completion and transmission to mitigate the possibility of having to bill default. The phrase "until a new assessment has been completed and accepted" can be troublesome as well. The final implementation memo, posted in the 'resources' section of my website says this:
"The new RUG code should not be billed until the MDS assessment has been completed and accepted in the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system. Once the MDS submission is transmitted and accepted, the new RUG should be billed retroactive to the Assessment Reference Date (ARD) for the MDS submission for the RUG."
So, I believe they mean this: If the ARD is late, you bill the default rate for the number of days it is late. You can't bill at all until the MDS has been accepted. I do not think they mean that there is a direct financial penalty for late 'completion' or late 'transmission.'
Additionally there are some troublesome issues in this Q&A. For example, it alludes to "opening" the assessment, but they seem to mean "setting the ARD." I don't think they have finished refining this yet. It is prudent to strive for timely ARD, completion and transmission to mitigate the possibility of having to bill default. The phrase "until a new assessment has been completed and accepted" can be troublesome as well. The final implementation memo, posted in the 'resources' section of my website says this:
"The new RUG code should not be billed until the MDS assessment has been completed and accepted in the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system. Once the MDS submission is transmitted and accepted, the new RUG should be billed retroactive to the Assessment Reference Date (ARD) for the MDS submission for the RUG."
So, I believe they mean this: If the ARD is late, you bill the default rate for the number of days it is late. You can't bill at all until the MDS has been accepted. I do not think they mean that there is a direct financial penalty for late 'completion' or late 'transmission.'
Here is the link to the official document, revised yesterday:
http://www.dmas.virginia.gov/Content_atchs/pr/NF%20Price-Based%20FAQs%20as%20of%2010%2027%2014%20%282%29.pdf
I have been asking many questions to our state representatives. I do not believe they fully understand the difference between late ARD, late completion, late transmittal, etc, so I am asking for your help. If you also find that questions arise when you read the final memo and the new FAQ document, please ask DMAS at this email: NFPayment@dmas.virginia.gov.
If they hear from all of you, instead of just me, it may prove to them that they need to clarify more items.
I have been asking many questions to our state representatives. I do not believe they fully understand the difference between late ARD, late completion, late transmittal, etc, so I am asking for your help. If you also find that questions arise when you read the final memo and the new FAQ document, please ask DMAS at this email: NFPayment@dmas.virginia.gov.
If they hear from all of you, instead of just me, it may prove to them that they need to clarify more items.
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