Inaccurate MDS Coding of GLP-1 Therapy as Insulin
Penalty
Summary
The deficiency involves inaccurate completion of the Minimum Data Set (MDS) for two residents with diabetes, where their assessments were incorrectly coded to show they received insulin. For one resident, the quarterly MDS indicated that insulin injections were received on one day during the 7-day look-back period. However, the resident’s order summary showed a standing order for Ozempic, a GLP-1 receptor agonist, administered subcutaneously once weekly for type 2 diabetes, with no indication of insulin use during that period. Ozempic is not classified as insulin and therefore should not have been coded as insulin on the MDS. For the second resident, the quarterly MDS also documented that insulin injections were received on one day during the 7-day look-back period. Record review showed that this resident had previously been on insulin, which was discontinued months earlier, and was subsequently placed on Ozempic and then Mounjaro, both GLP-1 receptor agonists administered subcutaneously. The current order summary reflected a weekly Mounjaro injection, with no active insulin order. During interviews, the MDS Coordinator confirmed that Ozempic and Mounjaro are not insulin and should not be coded as such, and the Administrator stated an expectation that insulin be coded accurately on the MDS, confirming that the assessments did not accurately reflect the residents’ actual medication regimens at the time of assessment.
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