MDS Alert

"In cases where the last day of the Medicare Part A benefit, that is the date used to code A2400C on the MDS, is prior to Day 7 of the COT observation period, then no COT OMRA is required. If the date listed in A2400C is on or after Day 7 of the COT observation period, then a COT OMRA would be required if all other conditions are met. Finally, in cases where the date used to code A2400C is equal to the date used to code A2000, that is cases where the discharge from Medicare Part A is the same day as the discharge from the facility, and this date is on or prior to Day 7 of the COT observation period, then no COT OMRA is required. Facilities may choose to combine the COT OMRA with the discharge assessment under the rules outlined for such combination in Chapter 2 of the MDS RAI manual."

CMS also clarified when you can do the EOT-Resumption OMRA: "To be considered an appropriate resumption of therapy, two qualifications must be met. First, the resident must resume therapy at the same RUG-IV therapy level as was in effect prior to the break in therapy... Second, the resident's previous therapy plan must still be in effect. For example, if the resident qualified for Very-High rehabilitation on the basis of receiving Physical and Occupational therapies, then these disciplines must resume at the same intensity as prior to the break in therapy. If, for a given resident, one or both of these two conditions are not met, then an EOT-R may not be completed for that resident," CMS states in the clarification document.

"For example, if the resident would resume at Very-High rehabilitation, but instead of receiving Physical and Occupational therapies the resident is expected to receive Occupational and Speech-Language therapies, then this would not constitute a legitimate resumption and an EOT-R could not be completed."

"If requested, covered entities that are the subject of complaints must produce evidence of either compliance or a good faith effort to become compliant with the new HIPAA standards during the 90-day period," CMS says in its statement.

To read the complete CMS announcement, visit www.cms.gov/ICD10/Downloads/CMSStatement5010EnforcementDiscretion111711.pdf.

Keep pain on your radar screen. Diane Atchinson, RN-BC, MSN, ANP, RAC-CT, says that she's conducted mock surveys and identified where "during the reference period for an MDS, the staff has coded that the resident had moderate to severe pain. Then you look to see if the nursing staff did an in-depth review of the pain issue, including pain medication in use and recommendations to the physician regarding adjusting the program -- and the answer is no."

Also: "Facility staff often assess for pain, add a routine or PRN pain medication, but then don't reassess until the next MDS is completed," adds Atchinson, president of DPA Associates Inc. in Springfield, Mo. "Facilities can obtain best practice data regarding pain management from their state QIO organization," Atchinson advises.

Do your residents need these vitamin and mineral supplements? One is vitamin D. People's "vitamin D [levels] go down with aging," said John Morley, MD, in a presentation on OTC supplementation and medical foods at the March 2011 American Medical Directors Association annual meeting. And "if you can find one person in your nursing home who is not 'vitamin D deficient,' certainly if you use 30 ng [per ml as a cutoff] -- that is a miracle." He also noted that "vitamin D deficiency is related to hip fracture and sarcopenia."

Remedy: "Someone can go in the sun one half hour day without sunblock and get enough vitamin D3 -- or you can supplement," says Morley, director of the division of geriatric medicine at St. Louis University School of Medicine in St. Louis, Mo. "We give everyone 1,000 units a day. Studies show that somewhere between 400 units and 650 actually works. And there's no such thing as a 650-unit dose, so you can give 800" units instead, Morley tells Eli.

What about calcium? "We know that calcium improves bone mineral density," said Morley in his talk. If a person requires calcium supplementation, he advises giving the calcium tablets at night. That's because "while people sleep, calcium comes off their bone when they are lying flat," Morley tells Eli.

Also: "If you give the calcium [supplements] with medications, the medications won't be absorbed. That's one reason you see study data associating calcium supplements with myocardial infarction. It blocks all the meds that prevent acute MI," says Morley, who also discussed that problem in his AMDA conference presentation.

Also: "Magnesium deficit can occur in some people -- most commonly in those with diabetes or on diuretics," warns Morley. "You need to pay attention to that and test for it. Weakness is probably the [major] symptom you will see, and the person won't feel good. Constipation is another one. Anytime you see constipation, you should test for magnesium" levels, adds Morley.

Researchers recently discovered that "high blood pressure and other known risk factors for stroke also increase the risk of developing cognitive problems, even among people who have never had a stroke," states a press release from the National Institutes of Health, which funded the study.

"Our results emphasize the importance of early intervention to treat high blood pressure and preserve cognitive health prior to a stroke or other cerebral event," said first author Frederick Unverzagt, PhD, in the release.