Patti Garibaldi, RN, BA, Director of Clinical Consulting

Question:  If therapy does not start right away on day of admit, am I required then to do a Start of Therapy PPS MDS?

Answer:  A Start of Therapy MDS (SOT) is an optional non-scheduled assessment.  MDS 3.0 no longer has section T in order to project a RUG into a therapy RUG category.  A Start of Therapy PPS MDS is only used to get a residents RUG score into a Rehabilitation Extensive Services or Rehabilitation RUG category.  It is optional.  If you are able to complete your 5 days of therapy within the time frame allowed (day 5 or up to day 8 utilizing grace days) then you would do a normal 5 day PPS MDS and your RUG will classify into a therapy RUG rate for all the reimbursement days.  If therapy is not provided for various reasons (resident refuses, resident is ill, for example), then you may want to consider doing a Start of Therapy PPS MDS.  You need to complete this assessment 5-7 days after the Start of Therapy date noted in Section O of the MDS.  Please remember that if this is done after the grace day period, you will also need to complete a 5 day PPS assessment that will place you into a non-therapy RUG classification.  Once a Start of Therapy PPS assessment is completed, the RUG reimbursement will start on the day that therapy began.  See RAI manual Chapter 2

Question:  We were always told to watch our grace days.  Can we still use them and is there a penalty?

Answer:   Grace days are to be utilized to maximize the benefit of services to the resident.  There are no penaltys to using grace days.  There may be situations when an assessment might be delayed (e.g., illness of RN assessor, a high volume of assessments due at appoximately the same time) or additional days are needed to more fully capture therapy or other treatments.  There has been no changes in the allowed grace days from MDS 2.0 to MDS 3.0.  Grace days, however, are not applied to unscheduled Medicare PPS Assessments (refer to RAI manual chapter 2 page 41)

Question:  Do I have to do a entry tracking record on every resident?

Answer:  Yes, you have to do entry reporting on each resident.  there are two types of entries that you may utilize: Admission and reentry. 
      1.  The Entry Tracking record is the first item set completed for all residents
      2.  Must be completed every time a resident is admitted (admission) or readmitted (reentry) into a
           nursing home
      3.  Must be completed for a respite resident every time the resident enters the facility.
      4.  Must be compelted with 7 days after the admission/reentry
      5.  Must be submitted no later than the 14th calendar day after the entry
      6.  Required in addition to the initial Admission Assessment or other OBRA or PPS assessments
           that might be required
      7.  Is a stand alone tracking document
      8. MAY NOT be combined with an assessment
See chapter 2 pages 32 and 33 of the RAI manual