Inaccurate Resident Assessments in MDS Documentation
Penalty
Summary
The facility failed to ensure accurate assessments for four residents during a recertification survey. For three residents, antiviral medications were incorrectly documented as antibiotics in the Minimum Data Set (MDS) assessments. This error was attributed to the electronic medical record system, which automatically classified antivirals as antibiotics. Interviews with the Nurse Unit Manager, MDS Coordinator, and Director of Nursing revealed a misunderstanding of the classification of antiviral medications, which was not aligned with the Resident Assessment Instrument manual or Centers for Medicare and Medicaid Services guidelines. Additionally, the assessment for another resident inaccurately documented a diagnosis of Non-Alzheimer's Dementia, despite the resident having no such diagnosis in their medical records. The resident was noted to have mild cognitive impairment but was alert and oriented. The error was made by the Nurse Unit Manager, who checked off the dementia diagnosis in the MDS assessment. Interviews with the Physician Assistant and Director of Nursing confirmed the absence of a dementia diagnosis in the resident's medical records.
Plan Of Correction
Plan of Correction: Approved January 3, 2025 **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Immediate Corrective Action: -The MDS coordinator on 12/06/2024 corrected immediately the deficiencies identified to accurately reflect the residents’ clinical diagnoses. The antibiotic checkbox was unticked for Resident #1, Resident #36, and Resident #42, and the corrected MDS was re-submitted to CMS. The MDS for the affected resident #54 was also immediately reviewed, corrected to remove the non-Alzheimer’s dementia diagnosis, and re-submitted to CMS. The error did not affect the residents’ quality of care at the facility. -The DON on 12/06/2024 held an IDT team huddle with the facility’s physician, physician assistant #1, unit RN managers, and individually informed the affected residents of the coding error and the corrective actions taken. -The IDT team from 12/06/2024 to 12/11/2024 performed due diligence in assuring that no care plan changes or interventions were affected by the incorrect coding, and no adverse impact occurred. No additional residents were inaccurately documented during the prior MDS submissions from 08/2024 to 11/2024. -The Compliance team on 12/12/2024 reviewed the facility’s Minimum Data Set Functional Coding Policy. No amendments were needed. Identification of Others Potentially Affected: -The facility respectfully submits all residents were potentially affected by this practice, after reviewing MDS records. System Changes to Prevent Recurrence: -The MDS coordinator was re-in-serviced on proper Section N (Medications) coding procedures, emphasizing accuracy and review processes. Training included the importance of cross-referencing the MAR indicated [REDACTED] facilitated by the compliance officer. In addition, training was also provided for proper coding for Section I (Active Diagnoses), including verifying [DIAGNOSES REDACTED] resident’s medical record before coding. -Subsequent to a root cause analysis, the Administrator contacted the MDS software vendor on 12/10/2024 to address the automated logic or interface issues causing incorrect antibiotic selection. Thus, implementing software updates or adjustments to prevent related errors. -The DON on 12/10/2024 instituted a secondary review process for all MDS submissions: A designated staff member (Senior RN Manager or ADON) will verify accuracy before all submission. Quality Assurance Monitoring: -The DON will conduct weekly audits of 10% of MDS submissions for the next 90 days to ensure accuracy in functional coding, with special focus on Section I and Section N. Findings will be reviewed during monthly QA meetings, and adjustments to processes will be made as necessary. -The Performance Metrics is set at a goal of 100% compliance with accurate MDS coding. Any errors identified during audits will be addressed immediately. -Audit tool has been created and implemented for ongoing monitoring. Responsible Party: Minimum Data Set Coordinator