MDS Alert

This aspect would remain the same, says CMS official.

The FY 2012 proposed SNF PPS rule shaves some days off the assessment reference date (ARD) windows for scheduled PPS assessments except for the 5-day or readmission/return assessment.

That assessment would still have an assessment window of days one through eight, says Peter Arbuthnot, RAC-CT, regulatory analyst for American HealthTech in Jackson, Miss. "But the 14-day PPS assessment has changed from days 11 to 19 to days 13 to18; the 30-day assessment is 27 to 33 instead of 21 to 34," he adds. (See the chart on page 70 of this issue comparing the current and proposed windows.)

"The MDS lookback periods [for the various MDS sections] aren't changing," however, Arbuthnot adds.

Good news: The proposed revision doesn't do away with grace days, CMS' Sheila Lambowitz assured those listening to the May 2011 SNF/LTC Open Door Forum. Consultant Pauline Franko, PT, MCSP, in Tamarac, Fla., predicts, in fact, that if the revised assessment windows go into effect, SNFs will use more grace days.

Survival tips: To keep track of the revised ARD windows, if they materialize, Elisa Bovee, MS, OTR/L, recommends therapy managers "work closely with their software vendors" to make sure they update the billing and therapy software to "flag anytime an ARD is entered outside the new window."

Therapists and MDS staff should also post the new schedule in "in a very conspicuous place within both departments" until staff memorizes the new schedules, adds Bovee, VP of operations for Harmony Healthcare International in Topsville, Mass.