Use of the MDS is Waived for CAH
Swing-Bed Patients
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of BQA 02-007 (PDF, 9 KB)
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Date: February 14, 2002
DSL-BQA 02-007
To: Hospitals HOSP 02, Critical
Access Hospitals (CAH) CAH 01
From: Jan Eakins, Chief, PRQI, Bureau of Quality
Assurance
cc: Susan Schroeder, Director, Bureau of Quality
Assurance
On February 1, 2002 the Centers for Medicare and Medicaid Services
(CMS) issued a memo that waived the requirement at 42 CFR, section 485.645
that required the use of the long term care Minimum Data Set (MDS) for
patients receiving post hospital skilled nursing facility (SNF) care. A
copy of the CMS letter announcing this change is attached to this memo.
Facilities should note that the CMS action does NOT eliminate the
requirement that CAHs complete an assessment and a comprehensive care plan
for each SNF patient, only the requirements that the MDS instrument be
completed as part of the assessment.
The effective date of this change in enforcement policy is February 1,
2002. Should you have questions, please contact Billie March, RAI
Education Coordinator, at the above address [Bureau of Quality
Assurance, PO Box 2969, Madison, WI 53701-2969] or via email at marchba@dhs.state.wi.us.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Ref: S&C-02-17
DATE: February 1, 2002
FROM: Director, Office of Clinical Standards and Quality
Director, Survey and Certification Group, Center for Medicaid and State
Operations
SUBJECT: Completion of Minimum Data Set (MDS) in Critical Access
Hospitals (CAHs)
TO: Associate Regional Administrators, DMSO; State Survey Agency
Directors
The purpose of this memorandum is to notify states and regional offices
of a change in enforcing the Minimum Data Set (MDS) requirement for CAHs
with swing-beds. The regulations at 42 CFR, section 485.645 provide that
in order for a CAH to use its beds to provide post-hospital skilled
nursing facility (SNF) care, it must be in "substantial
compliance" with nine SNF requirements contained in 42 CFR, section
483, subpart B. Included in those regulations are requirements for CAHs to
complete the full MDS as part of their assessment of patients in CAH
swing-beds.
We have analyzed the current significance of this requirement and
concluded that the MDS compliance burden on these small facilities can be
reduced without jeopardizing patient health and safety. CMS will consider
CAH facilities that meet all but the MDS SNF requirements to be in
substantial compliance with the CAH swing-bed regulations.
We will still require CAHs to complete a resident assessment and a
comprehensive care plan for each SNF patient and document the assessment
in the medical record. However, we will not require CAHs to use the MDS
instrument for the resident assessments.
Effective Date: This enforcement policy change is effective
immediately.
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