Timing Requirements for an Admission MDS
The timing for an admission Minimum Data Set (MDS) is governed by strict regulations established by the Centers for Medicare and Medicaid Services (CMS). The process begins with the resident's admission date, considered day one, with the comprehensive admission assessment due by the 14th calendar day.
The Assessment Reference Date (ARD)
The Assessment Reference Date (ARD) is crucial, serving as the final day of the data collection period. For an admission assessment, the ARD must be set no later than the 14th day of admission.
Multistep Completion Process
Completing the admission MDS involves several steps within the 14-day window: finalizing the MDS, completing Care Area Assessments (CAAs), and developing the care plan within seven days of CAA completion. Both the MDS and CAA completion must occur within the 14-day limit.
Comparison: OBRA vs. PPS Timing
Facilities often combine the OBRA Admission assessment, due by day 14 for all residents, with the 5-Day PPS assessment required for Medicare Part A residents for reimbursement classification. The 5-Day PPS assessment has an ARD set between days 1 and 8.
| Assessment Type | Purpose | Timing Requirements | Combined with OBRA Admission? |
|---|---|---|---|
| OBRA Admission | Comprehensive assessment for all residents funded by Medicaid, Medicare, or private pay. | Must be completed by day 14 of admission. ARD set no later than day 14. | Yes, facilities can strategically set the ARD to align with PPS requirements. |
| 5-Day PPS | Establishes the initial case-mix classification for Medicare Part A reimbursement. | Must be completed by day 14 of the Medicare-covered stay, with ARD set between days 1 and 8. | Yes, this is a common and efficient practice to meet both requirements. |
| Interim Payment Assessment (IPA) | Optional assessment to adjust payment if a resident's clinical status significantly changes during their stay. | Timing is flexible based on the resident's change in condition, with a 14-day completion rule from the ARD. | N/A. This is a separate, optional assessment. |
| Quarterly | Non-comprehensive assessment to monitor ongoing resident status. | Due within 92 days of the previous OBRA assessment's ARD. | N/A. This is a routine, subsequent assessment. |
Special Circumstances That Trigger an Admission MDS
A new admission MDS is required for a resident's first stay or if they return after a 'return not anticipated' discharge. It's also needed if a resident returns after being discharged before the initial admission assessment was completed. This differs from a 'return anticipated' discharge where a tracking record is used instead.
Consequences of Failing to Meet Deadlines
Failing to meet the 14-day deadline can lead to financial penalties, as timely submissions are required for Medicare and Medicaid payments. Non-compliance can result in citations, fines, and sanctions. Delayed assessments also negatively impact resident care by hindering the development of an accurate care plan.
The Role of Technology and Internal Processes
Facilities use MDS software to track deadlines and streamline data entry. Effective processes include designating an MDS coordinator, clear communication protocols, and "triple check" meetings for accuracy.
Conclusion
CMS clearly mandates that an admission MDS be completed within 14 calendar days of a resident's admission. This timeframe includes completing the MDS, CAAs, and the care plan within the subsequent seven days. Meeting this deadline is vital for reimbursement, regulatory compliance, and providing quality resident care. Understanding the nuances of OBRA and PPS timing, as well as triggers for new admission assessments, is essential for facilities.
Learn more about MDS regulations
For additional detail and official guidance on the MDS process, refer to the {Link: CMS website https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/nursinghomequalityinits/mds30raimanual}.
