DOH Publishes MDS Audit Guidance
The Department of Health (DOH) has posted a guidance document that seeks to clarify MDS requirements, specifically documentation standards, that the Office of the Medicaid Inspector General (OMIG) uses during MDS audits. The Dear Administrator Letter (DAL) that announces the posting is available here. The clarification document itself is available on the DOH website here.
The guidance was developed with input from LeadingAge NY and other associations as part of discussions with DOH and OMIG. It was created to clarify audit terminology and MDS documentation requirements and is designed to be used along with the RAI manual. We had requested such clarification when MDS audits first began several years ago and are pleased that it is being released.
The document brings together the most pertinent information for each section with references as to where to find further clarification inside the RAI manual. It also provides the minimum documentation requirements that support the coding into the MDS. Activities of Daily Living (ADLs) and therapy services have been a particular focus of the audits, and the guidance addresses both in detail. Members may want to print this guide and make it available as a reference for any discipline that submits data into the MDS.
At this time, OMIG is completing the round of 2016 MDS audits and issuing final audit reports for 2015 audits. DOH expects to issue July 2015 and January 2016 rates reflecting findings from 2015 MDS assessment audits later this year, which will also include the removal of the 5 percent CMI change constraint for those impacted.
It is unclear exactly how the case mix adjustment process for Medicaid rates will work going forward. The State no longer publishes CMI picture dates in advance and has not announced which MDS assessments will be used for purposes of adjusting January 2019 Medicaid rates. Although the CMI used in the July 2018 rates was based on a Jan. 31st picture date (i.e., the last Wednesday of January, as in prior years), DOH did not confirm that date until February. Driven by a state budget provision that requires $15 million in CMI savings, the State is working on developing an alternative approach with Deloitte, its actuary. We will continue to urge DOH to let providers know their intentions as quickly as possible to resolve the current sense of uncertainty.