The IMPACT Act requires that CMS implement cross-setting quality measures. These items assess the need for assistance with self-care and mobility activities. You don't need to know the coding process, but you should share this type of information with your MDS team so that they are compliant with the new regulations for section GG under the IMPACT act.
The SNF QRP will begin collecting data from MDS assessments (and section GG) on October 1, 2016. The good news is that Section GG only applies to residents admitted to a skilled stay in your community! It must be completed at the time of admission and at the time of discharge. If you're combining an Admission assessment with a 5-day assessment, complete both Sections G and GG. The look-back period for this assessment is days 1-3, starting with the start of the most recent medicare stay.
What Does Section GG Say?
Section GG Items – Rationale:
- GG0130 – Self-Care – During a Medicare Part A stay, residents may have self-care limitations on admission. In addition, residents may be at risk for further functional decline during their stay.
- GG0170 – Mobility – Residents in Medicare Part A stays may have mobility limitations on admission. In addition, residents may be at risk of further functional decline during their stay.
There are 3 columns in section GG0130:
- Admission performance. This assessment is completed between day 1 and day 3 of admission
- Discharge goals. This assessment is completed between day 1 and day 3 of admission
- Discharge performance. This assessment is completed within 3 days of discharge
Admission Assessment and Discharge Goals
Licensed clinicians can establish a resident’s discharge goals at the time of admission based on discussions with the resident and family, professional judgment, and the professional’s standard of practice. Goals should be established as part of the resident’s care plan. Clinicians may code one goal for each self-care and mobility item included in Section GG at the time of the 5-day PPS assessment. A minimum of one self-care or mobility goal must be coded per resident stay on the 5-day PPS assessment.
The instructions state to assess the resident’s self-care status based on direct observation, the resident’s self-report, family reports, and direct care staff reports documented in the resident’s medical record during the 3 day assessment period. If “helper” assist is required because the resident’s performance is unsafe or of poor quality, only consider staff assistance when coding according to the amount of assistance provided.
“Helper” is a new term to us – it's defined as “facility staff who are direct employees and facility contracted employees (i.e., therapy staff, contract/agency staff)." It does not include individuals hired, compensated or not, by individuals outside the facility management and administration such as hospice staff, nursing or CNA students, etc. This would also include family members and “sitters” hired by the family.
Discharge – End of Stay
This assessment is completed when a resident has a planned discharge from the SNF Part A stay. It is not completed when a resident is discharged to the hospital BUT the GG Admission assessment is required with each new admission/readmission. When the resident has a planned discharge, the look-back period for this assessment is the last 3 days prior to the discharge, including the discharge date. These items will indicate the resident’s performance ability at the time of their discharge from an SNF stay.
Item set coding for Section GG is very different from what we're used to seeing in Section G. If you've been involved in SNFs for a long time, you might be more familiar with the coding as it seems to be therapy lingo and functionally driven. This is a true functional assessment and you need to involve your therapy team when you're coding these items.
Although Section G allows for the use of dashes in the coding, this is highly discouraged in Section GG unless there are absolutely no other options. Dashing a response instead of using the appropriate corresponding coding could result in your QM data not being generated, which could result in a loss of payment! Remember, a dash means “no information”!
Some Coding Tips
- Assistive Devices – Activities can be completed with or without an assistive device. Use of assistive devices should not impact the coding on the activity.
- Residents should be coded performing activities based upon their “usual performance” or baseline performance, which is defined as the resident’s usual activity/performance for any of the self-care or mobility activities, NOT the most independent performance and NOT the most dependent performance over the assessment period.
- Read each instruction for the coding of item sets very carefully; Section GG of the RAI, Chapter 3, GG1-31 offers very clear instructions and some excellent examples on coding.
- Do not record the staff’s assessment of the resident’s capability to do an activity; only code the actual performance.
- Involve your therapy staff on Section GG – they understand the lingo very well and can assist you in understanding the functional assessments.
- Teach your direct care staff the basics. It’s very difficult to get them to code Section G now, but sometimes teaching them new things are easier and you get better buy in!
- If you aren’t already having PPS meetings to discuss discharges, now is the time to start!
Remember, your best resource for coding, timelines, and overall requirements is the MDS 3.0 Item Set.
Next Steps
- Learn more about the SNF Quality Reporting Program
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