MDS Alert

Here's the posted solution for now.

The Centers for Medicare & Medicaid Services' has heard providers' concerns about having no way to explain on the MDS that they offered a resident a flu or pneumococcal vaccination but weren't able to provide it by the ARD.

Because none of the coding options in W2b or W3b currently explains that scenario, CMS has posted the following instructions on the www.qtso.com FAQ site.

Q: How do I code item W2b on the MDS if the resident has not received an influenza vaccine by the ARD, and none of the reasons in W2b apply?

A: As is the case with most of the MDS items, item W2b allows an "unable to determine" value (a dash). If none of the reasons in item W2b apply, the "unable to determine" value (a dash) should be coded.

Q: How do I code item W3b on the MDS if the resident's PPV status is not up to date by the ARD, and none of the reasons in W3b apply?

A: As is the case with most of the MDS items, item W3b allows an "unable to determine" value (a dash). If none of the reasons in item W3b apply, the "unable to determine" value (a dash) should be coded.

Q: If the facility knows that their supply of flu vaccine won't be available by the ARD date, how should item W2b be coded?

A: Before choosing a response, determine whether the vaccine is unavailable because of a declared vaccine shortage (as described in the RAI user's manual) or because the vaccine supply is expected to be delivered after the ARD. If the resident was offered the vaccine by the ARD but the vaccine is unavailable at the facility due to a declared vaccine shortage (as described in the RAI manual), then code response 6, "Inability to obtain vaccine."

If the resident was not offered the vaccine by the ARD because the vaccine is unavailable due to a declared vaccine shortage (as described in the RAI manual), then code response 6, "Inability to obtain vaccine."

If the resident was offered the vaccine by the ARD, and the facility knows it will receive its supply of vaccine after the ARD, a response of "unable to determine" (a dash) is allowable.

The bottom line: When responding to W2b and W3b first read and consider all the responses listed for each. If none of the listed responses apply, a response of "unable to determine" (a dash) is allowable, states the posted information at www.qtso.com/mdsfaq.html# sectionFAQs.

Providers have expressed gratitude for CMS' willingness to address their coding concerns in the light of a final immunization regulation issued in October requiring facilities participating in Medicare and Medicaid to educate residents/responsible parties about the flu and pneumococcal vaccines and then offer residents the immunizations, if they are eligible to receive them and agree to do so.

"When MDS coding instructions come out, there always seems to be those that don't fit perfectly into the mold. So any future clarifications are always helpful," says Lisa Marcincavage, CRNAC, an MDS nurse with Little Flower Manor in Wilkes-Barre, PA.