Harmony Healthcare International (HHI) Comments on Section GG and Inter-Rater Reliability

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Company Raises Questions About Possible Confusion and Conflicting Information Among SNFs

“We have concerns that an attempt to standardize patient assessment and quality measures may have, inadvertently, added to the confusion with measures that may impact inter-rater reliability.”

October 1, 2016 will bring radical changes for SNFs across the country with the launch of the revised Minimum Data Set (MDS) Sections A and the new Section GG. SNF administrative teams will be challenged at the end of Medicare Part A stay to broaden their understanding of the internal systems and processes that could make or break a facility’s quality outcomes.

“The intent is to connect post-acute care across the continuum, which should result in optimized patient care,” said Kris Mastrangelo, President and CEO, Harmony Healthcare International (HHI), “However, we have concerns that in an attempt to standardize patient assessment and quality measures, CMS may have, inadvertently, added to the confusion with measures that may impact inter-rater reliability.”

Harmony Healthcare International, a leader in compliance, reimbursement, regulatory and efficiency consulting in the SNF market segment has been long recognized as a trend influencer in the industry. Major changes in the MDS 3.0 Section GG include the addition of 16 new items for assessment representing half of the items included in the CARE item set and change in timing. Section GG Functional Abilities and Goals will be completed with each 5 day MDS PPS Assessment differing from the CARE tool which required a 2 day assessment period. Completion of “Admission Performance” and “Discharge Goal” for each of the 16 new items will be required with each 5 day PPS MDS. Only “Discharge Performance” will be required for each of the 16 new items for the SNF PPS Part A Discharge (End of Stay).

The assessor will have to code “the resident’s usual performance” for each of the 16 activities using the 6-point scale consistent with the CARE tool. If the activity was not attempted the assessor codes the reason why the activity did not occur: “Resident refused; Not applicable or not attempted due to medical condition or safety concerns.”

“It is primarily in the coding that we see the potential for problems with inter-rater reliability,” said Mastrangelo, “The new 6-point scale differs significantly from current MDS coding conventions for Section G ADLs. For instance, the 6-point scale in Section GG is the reverse of the scale in the long used Section G. In Section G, the lower the number the more independent the patient is, conversely in Section GG, the lower the number the more dependent the patient is on staff. Although the new terminology appears similar to therapy terminology, the definitions are, in fact, quite different.”

As the October 2016 deadline approaches, Harmony Healthcare International (HHI) is working with CMS to clarify and define coding to help make the transition seamless. “We will do all we can to use our expertise to educate industry on these upcoming changes,” added Mastrangelo, “With increased regulation, changes and the onset of value base purchasing, SNFs have to be prepared for and aware of the impact of these changes on a building’s quality measures.”

For more information visit: http://hhi.hub.am/2999vdV

About Harmony Healthcare International

Harmony Healthcare International (HHI) was founded in 2001. With headquarters in Topsfield, MA, Harmony Healthcare International (HHI) serves clients in the skilled nursing, acute care, home health and assisted living markets with operational and compliance consulting, training and educational programs and talent enrichment services. With a staff of accomplished HealthCARE Specialists who serve as consultants to For-Profit, Not-For-Profit, Standalone and Multi-Facility Chains across the country, Harmony Healthcare International (HHI) has been ranked among the top 5,000 fastest growing private companies in the U.S. for 3 consecutive years by Inc. Magazine. Harmony Healthcare International, “We C.A.R.E. About Care.”

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Jon Di Gesu
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