MDS Alert

Reader Question:

Decode Confusing New Discharge-Return-Not-Anticipated Instructions

Question: The October 2014 RAI Manual update added a new example for “discharge return not anticipated” in Chapter 2, page 35 that’s rather confusing. In the example, CMS states that I should code 2 in A2100 when the resident transfers from a Medicare-certified bed to a noncertified bed at our facility. This doesn’t make sense, because the resident doesn’t actually leave our facility. Can you explain?

Answer: The Centers for Medicare & Medicaid Services (CMS) did make this confusing, admits Marilyn Mines, RN, BC, RAC-CT, MDS Alert consulting editor and senior manager of clinical services for FR&R Healthcare Consulting Inc. in Deerfield, Ill.

The new example in the RAI Manual on page 35 of Chapter 2 reads as follows:

2. Mr. K was transferred from a Medicare-certified bed to a noncertified bed on December 12, 2013 and plans to remain long term in the facility. Code the December 12, 2013 Discharge assessment as follows:

A0310F=10
A2000=12-12-2013
A2100=2

By indicating 2 — Another Nursing home or swing bed for A2100 — Discharge Status, the MDS is stating that the resident is in a nursing facility but not in a certified bed, Mines says. “This is exactly what the explanation is saying — the resident did not go to any of the other choices, but is in a nursing facility.”

If the resident is readmitted, you’ll treat him as an entry (1 — Entry in A1700 — Type of Entry). 

The RAI manual tells you to Code 1 — Admission when one of the following occurs:

1. The resident has never been admitted to this facility before; OR
2. The resident has been in this facility previously and was discharged return not anticipated; OR
3. The resident has been in this facility previously and was discharged return anticipated and did not return within 30 days of discharge.

Then for A1800 — Entered From, you would code 2 — Another nursing home or swing bed, Mines instructs. You must do an Admission assessment; because the resident was discharge-return-not-anticipated, all records of prior assessments would move from the active client database.

Bottom line: Don’t get hung up on the fact that the resident is still in the physical building, Mines says. The resident is really “in the community,” because he is in a private area, not a certified bed. 

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