Inaccurate MDS Coding for Catheters, Insulin, Ostomy, Turning Programs, and Hospice
Penalty
Summary
The deficiency involves the facility’s failure to ensure accurate completion of the Minimum Data Set (MDS) assessments for multiple residents, contrary to the RAI 3.0 User’s Manual requirements for validated, interdisciplinary assessments over the defined look-back period. For one resident, the quarterly MDS indicated the presence of an indwelling catheter in Section H, even though observation and interview confirmed the resident did not have a catheter and reported it had been removed months earlier. Review of progress notes and physician orders showed the catheter had been discontinued the prior year, before the MDS look-back period. The MDS coordinator acknowledged that the catheter item was marked inaccurately and that the resident should not have been coded for an indwelling catheter. The facility also inaccurately coded insulin injections for two residents. One admission MDS showed seven days of injections and seven days of insulin injections in Section N, while the MAR and TAR for the look-back period documented insulin injections on only two days. For another resident, the admission MDS showed zero days of insulin injections, but the MAR and TAR documented insulin injections on seven consecutive days within the look-back period. In both cases, the MDS coordinator confirmed that the MDS coding did not match the documented administration of insulin and that the assessments were inaccurate. The DON stated an expectation that MDS assessments be completed accurately and acknowledged that these admission MDS assessments were inaccurate. Additional inaccuracies were identified for residents with ostomy status, turning/repositioning programs, and hospice/prognosis. One admission MDS coded an ostomy in Section H for a resident, yet provider orders, progress notes, and MAR/TAR contained no evidence of an ostomy device, and the MDS coordinator stated the resident never had an ostomy and that the MDS was not accurate. Another resident’s quarterly and annual MDS assessments were coded for a turning/repositioning program in Section M, but the care plan did not contain an active turning/repositioning program intervention, and the EHR lacked documentation that such a program was monitored or reassessed for effectiveness; the only related intervention had been resolved previously. The MDS coordinator stated there was no documentation to support the program and that the coding was inaccurate. For another resident, the EHR and hospice physician note documented admission to hospice services and a prognosis of six months or less, but the admission MDS did not code hospice services in Section O and marked “no” for a prognosis of less than six months in Section J1400. The MDS coordinator confirmed that hospice and prognosis should have been coded and that the MDS was inaccurate.
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