June 28, 2016 | Optima Healthcare Solutions

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Unlocking Section GG: Answers to the Burning Regulatory Questions

Is Section GG making your head hurt? Net Health Therapy for Skilled Nursing  is offering a regulatory remedy.

We’re answering the top twelve questions about MDS Section GG, so you can avoid frustration and wasted time searching for answers. Plus — share this with  staff in your Skilled Nursing Facility or Long Term Care facility for easy post-acute education!

Q: Who is responsible for completing MDS Section GG? 

A: The Impact Act mandated that the Centers for Medicare & Medicaid Services (CMS) establish a Quality Reporting System (QRP), wherein each long term care or skilled nursing facility (SNF) must submit data on quality measures. CMS created Section GG to capture the required quality measures for functional data reporting.

Thus, the Skilled Nursing Facility (SNF) is ultimately responsible for completing Section GG. However, due to the nature of the requirements around data collection, all core staff in long term care settings (including therapy) working with patients will be affected. This applies to inpatient rehabilitation facilities and post acute care settings.

Q: What patients should Section GG be completed on? 

A: Section GG must be completed on Medicare A PPS patients in inpatient rehabilitation facilities and post acute care settings.

Q: Should Section GG only be completed once? 

A: No. Section GG must be completed on the Evaluation, as well as the planned Discharge.

Q: In what context should Section GG MDS be completed? (Many patients perform better in a therapy setting than they do in a nursing unit.)

A: Per CMS, providers should refer to facility, Federal and State policies and procedures to determine which staff members may complete Section GG. Since Section GG is scored based on the patient’s usual performance, the data collection may be completed with input from nursing staff and/or therapy professionals; the assessment is based upon direct observation, patient self-report and direct care staff reports. Your interdisciplinary team in your inpatient rehabilitation facilities (physical therapy, occupational therapy) offering any level of assistance  should do a standardized assessment.

Q: How does CMS define usual performance?

A: The draft RAI manual defines usual performance (also referred to as baseline performance) as the resident’s usual activity or performance for any of the self care or mobility activities, NOT the most independent or dependent performance. Per CMS (during the SNF QRP training on June 21 – June 22, 2016), while the assessment period is the first and last three days of the SNF Medicare Part A PPS stay, reporting should reflect the patient’s admission status as close to day one as possible.

Q: When the patient is admitted to the SNF, do providers need to assess each self care and mobility Section GG item on every shift, across the first three days of the stay? 

A: No. During the SNF QRP training on June 21 – June 22, 2016, CMS training professionals confirmed that the data reporting expectation is the patient’s usual performance (i.e. admission status) and functional status as close to day one as possible. The data collection should provide a general picture of the patient’s baseline function before any improvement occurs.

Q: Who should determine the discharge goal? 

A: The QRP measure requires care plan data for each patient. This requirement is met by documenting at least one discharge goal item on Section GG for at least one self care or mobility item. The discharge goal does not have to be created by therapy (in some cases, that would not be appropriate) and should be based on results of the initial Section GG assessment and collaboration with the care plan team.

Q: Do I have to complete the CARE Item Set to comply with Section GG? 

A: No. Section GG is required by CMS but the CARE Item Set is not. Section GG does contain CARE items, which is why some therapy providers are choosing to require staff to complete the CARE Item Set as well.

Q: What are the differences between Section GG and the CARE Item Set? 

A: There are three main differences between Section GG and the CARE Item Set.

  • The definition of Dependent on the six-point scale: CMS added an additional caveat on Section GG that if assistance of more than one helper is required, then the task is scored as Dependent regardless of the percentage of assistance required.
  • Section GG has three numeric score options that can be used to classify the reasons for an activity not being attempted, whereas the CARE Item Set has four alpha scores.
  • Section GG includes a slightly different set of items than are used in the CARE Item Set.

Q: How do clinicians become CARE certified? 

A: Net Health Therapy for Skilled Nursing currently facilitates certification and CEU credits through its CARE Self Care and Mobility Item Sets curriculum, offered to physical and occupational therapists, as well as your interdisciplinary team. Contact Net Health to learn more about this curriculum and the assistance provided.

Q: What are the benefits of participating in CARE? 

A: Participating in CARE will allow you to contribute data to a national repository, giving you the opportunity to compare your organization to other providers. Plus, since clinician certification is required, you can trust the validity of the data.

Q: What should I expect from my vendor? 

A: Your vendor should ensure that the software enables you to implement Section GG requirements in the most efficient manner for your organization. This will vary depending on your unique needs, but at a minimum your vendor should:

  • Have facility-level configurability options regarding which patients your therapy staff will complete Section GG on, including:
  • All Medicare A PPS patients
  • Medicare A PPS therapy patients only
  • No patients
  • Allow for integrated CARE and Section GG MDS assessments
  • Create interoperability options that allow for read-only access of Section GG
  • Make reporting available so you can understand what your data says about your performance and patient care
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