CMS Policy Change for Assessment Submission Time Frame Announced Today

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

CMS posted this policy change today:

“The current CMS policy for submission of patient assessment records allows providers to submit records for up to 36 months from the assessment target date. Effective October 1, 2019, the CMS policy for patient assessment submission will be changed to 24 months from the assessment target date. The policy change applies to new, modified, and inactivated records.” (I’ve bolded and italicized the verbiage that applies to the new policy.)

The policy change notice was posted today on the QIES Technical Support Office’s News webpage.

This change impacts providers that submit MDS (SNF/LTC), OASIS (home care agencies), HIS (hospice), IRF PAI (inpatient rehab) and LTCH (long term care hospitals) assessment records/Item and Data Sets. There is no additional information provided by CMS at this time.

Previously, assessment records submitted by the above providers were available on the Federal database for 3 years/36 months in the event a record needed to be modified or inactivated. If an assessment record (i.e. Discharge Assessment) was not submitted, it could be submitted (albeit late) within that 3-year period to correct the Missing Assessment Report. This policy change reduces the availability of records retained on the Federal database to 2 years/24 months as of October 1, 2019.

The key takeaway from this policy change, to me, is to ensure that the assessment records you submit are accurate when you initially transmit them!   Accuracy should always be paramount with any such records as your reimbursement, survey, Nursing Home Compare, Five-Star rating as well as quality and other reporting measures depend on accurate data.   Watch final validation reports closely for warnings that are possible cues to inaccurate information and address any modification needed as soon as possible. Keep an eye on your Missing Assessment Report as well as other CASPER reports each month to ensure you’ve submitted all assessment records in a timely manner. The clock is ticking – as always – but louder now for timeliness!