MDS Data Verification Process Under Way

Nursing home members should be aware that the window for reviewing the Minimum Data Set (MDS) assessments that will be used for calculating the Case Mix Index (CMI) used to adjust July 2021 Medicaid rates is now open. Providers have until July 23^rd to review the data posted on the Health Commerce System (HCS) and ensure that the correct payer and special population information is reflected. Homes must email the signed and notarized certification to MDSBRHCR@health.ny.gov within seven days of pressing the “Submit” button indicating that their MDS data is correct. Certifications must be received by the Department of Health (DOH) no later than July 30^th. The Dear Administrator Letter (DAL) is available here; the certification form is here.

The July 2021 Medicaid rate marks the first time that the State is utilizing the new CMI methodology, which bases the calculation on all MDS assessments submitted during the six-month catchment period (i.e., Oct. 1, 2020 through March 31, 2021) instead of using the “picture date” approach. More information on the regulations implementing the methodology change is available here.

DOH reviewed the new process during a webinar on July 7^th. While the use of all MDS assessments with Assessment Reference Dates (ARD) that fall within a six-month period rather than a picture date approach may adversely impact rates, the process for verifying submitted MDS data is very similar to the one used previously. Providers need to navigate to the appropriate section of the HCS (see slides 18-20 of the DOH presentation) and review the list of assessments with ARDs within the catchment period. As in previous MDS verification cycles, providers will be able to update the payer status, the specialty unit indicator, as well as the special population flag (i.e., Dementia, BMI, TBI). Note that any changes made using the drop-down menus are meant to ensure that the information reflected is accurate at the time of the ARD of the assessment in question.

The slides used are available here, and DOH intends to post the entire webinar as well as a set of Questions and Answers on both the HCS and the regular DOH website here under the “MDS Case Mix Collection” heading. Highlights of the DOH presentation as well as key information regarding the new process include:

All MDS assessments will be used in the calculation as long as:
- The ARD is between Oct. 1, 2020 and March 31, 2021;
- Medicaid is the payer at the time of the ARD;
- The assessment provides sufficient information to generate a Resource Utilization Group (RUG) score.
All MDS assessments meeting the criteria above will be used in the calculation, including those filed for residents who have since been discharged.
The CMI will be calculated by averaging all of the RUG score weights for assessments that meet the criteria above.
Assessments will not be day-weighted. In other words, the RUG score weights from all assessments meeting the criteria above will be summed and divided by the total number of assessments filed.
Assigning “default” scores will no longer be necessary, since the calculation will focus on all filed assessments, not require resident matching.
Consistent with prior practice, the following payers are included in the CMI calculation: Medicaid fee-for-service (FFS), Medicaid pending, Medicaid Managed Care, and Managed Long Term Care (MLTC), including Programs of All-Inclusive Care for the Elderly (PACE) and Medicaid Advantage Plus (MAP).
The MDS certification form must be signed by the Administrator or an officer of the organization, be notarized (a new requirement), and be submitted by email to MDSBRHCR@health.ny.gov.
DOH will no longer apply a temporary constraint limiting the CMI increase or decrease to 5 percent relative to the previous CMI measurement cycle.
DOH is accepting questions at MDSBRHCR@health.ny.gov but reminds providers to use secure transfer application addressed to BLTCRMDS Group if sending resident-identifying information (instructions for using secure transfer appear on p. 24 of the slides).

While we continue to advocate that the methodology change be delayed until after the pandemic, we recommend that members be prepared for the change to be made effective with July 2021 rates. Members who might face significant rate decreases are encouraged to contact us.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841