Providers warned to prepare for April changes to RAI manual

If the only certainty in this life is change, as the saying goes, then LTC providers are among the most assured people on the planet as they navigate the ever-changing landscape of the RAI (Resident Assessment Instrument) process.

And more changes are coming April 1, 2012, with key adjustments to the RAI process that will impact the MDS 3.0 and billing. These changes are significant and require MDS managers and members of a SNF’s interdisciplinary team to be aware of their individual roles in facilitating change, advised Leah Klusch, RN, BSN, FACHCA, executive director, Alliance Training Center, in a Long-Term Living webinar she presented today.

Klusch attended the 2012 MDS 3.0 National Conference in St. Louis last week where representatives from CMS (Centers for Medicare & Medicaid Services) presented positions on the April updates and policy changes. At that meeting, some procedural and definitional issues created heated discussion challenging CMS staff, reported Klusch. As a result, some issues may be amended by April 1 or soon thereafter.

For example, currently one can correct or modify an assessment and keep the ARD (assessment reference date); it’s a simple process. However, CMS announced that going forward inactivations would require a totally new assessment, reported Klusch, and result in the inability to bill for the first part of the assessment, and a loss of reimbursement. “As a result of the negative response, this may be amended,” said Klusch. “They [CMS] assured us they’d review this policy and we’re hoping they’ll either issue a clarification, change it or delay it.”


The definitions for many terms and items in the RAI have been changed. Some of the changes are clarifications and assist the team to document issues and items with more clarity.

“Make sure you have all the updated information in your manual and be updated to the errata document of March 12,” advised Klusch. “You must use the manual to code because there are so many definitional changes.

“Also, [providers] should have copies of the data set for their teams to look at. It’s not enough to just talk about the changes. Make copies of the data set for people.”

Some of the changes will only affect MDS coordinators, said Klusch, while others are very interdisciplinary. For example, “there are enormous changes to section Q,” said Klusch. “It’s essentially rewritten with all new directions and new criteria. Be careful because the team has to decide who will manage that change.”

And, while CMS didn’t change the resident interview format, Klusch emphasized that training should focus on how interviews are being conducted. “Documentation of interviews is very important," said Klusch. "You have significant responsibility in documenting when you do the interviews. While [CMS] didn’t change much about the section, they changed some things in the appendix so be careful in getting the interviews done. CMS is really focused on that.”

Klusch offered suggestions on how to manage errors and changes in version 1.08 of the RAI manual:

  • Get the proper change documents.
  • Check all areas of the manual for errata information and follow-up.
  • Take the time to carefully review the changes and the errors; make sure the team understands.
  • Providers need to be in touch with their software vendors to know when the updates will arrive and be efficient in getting them downloaded.
  • There may be more error messages or changes from CMS—stay tuned.

“Take a good look at your schedule for late March and April,” advised Klusch. “Manage the changes and be sure the team knows when to gather data using the new definitions and items.

“If you do not use the proper data set and software after April 1, 2012, the data sets will not validate,” said Klusch. “This is a big problem. You need operational support and budget for this transition. Do not try to do this by yourself.” 


Long-Term Living webinar: “Managing Change in Your Assessment Process: An Overview of the April 2012 Changes to the RAI Manual”

Website to access MDS RAI manual

Website to access Appendix PP (guidance to surveyors)

Corrected MDS 3.0 RAI Manual (v 1.08) Errata document

Topics: Articles , MDS/RAI , Regulatory Compliance