This week’s “Ftag of the Week” on the CMSCG Blog is a tag that we’re unfortunately seeing an increasing number of citations under, F640 Encoding/Transmitting Resident Assessment. Consider this a friendly reminder from the CMSCG Team about getting your assessments in timely!
During survey, if there is reason to suspect that assessments are not being completed and submitted as required, surveyors are directed to verify submission into iQIES reviewing the facility’s MDS Final Validation Report.
Regulatory Requirements
The requirements for F640 are simple. Facilities are required to:
- Encode MDS data for all residents in the facility
- Electronically submit MDS data to CMS for every resident
- Edit the encoded data to ensure it meets required specifications
There are two main purposes of this regulation. The first, of course, is essentially payment related. Facilities are required to provide specific resident information for payment purposes as well as QM purposes. The requirement is also in place to assist facilities with monitoring changes to residents’ health data over time.
F640 – Requirements & Timeframes
Appendix PP of the State Operations Manual contains a handy list of reminders about what needs to be coded and transmitted. Submissions must be in accordance with both State and Federal timeframes and include MDS and CAA Summaries, where applicable.
- Facilities have to encode the following within 7 days of completion of a resident’s assessment: admission assessment, annual assessment update, Significant change assessment, quarterly review assessment, items required upon a resident’s re-entry, transfer, discharge or death, and background information (if there is no admission assessment).
“Background Information” is defined in this regulation as the MDS Entry tracking record, which is based on face sheet information.
There are a couple of key date determinations in the Interpretive Guidance for F640 for you to be aware of:
Comprehensive Assessments
Comprehensive Assessments include Admission, Annual, Significant Change and Significant Correction to Prior Comprehensive assessments. If a comprehensive assessment is completed, encoding must occur within 7 days after the Care Plan Completion Date (V0200C2 + 7 days).
Other Assessments
For other assessments, including Quarterly assessments, Significant Correction to Prior Quarterly, Discharge assessments or PPS assessments, encoding must occur within 7 days after the MDS Completion Date (Z0500B + 7 days).
Tracking Records
For tracking records, the encoding requirements are within 7 days of the Event Date:
- Entry records (A1600 + 7 days)
- Death in Facility records (A2000 + 7 days)
Facilities have 7 days after the completion of a resident assessment to ensure it can submit the data coded in the MDS to CMS. The data must be formatted in the required standardized format.
F640 – Submission Requirements
Within 14 days of completion of the resident assessment, the facility must electronically transmit MDS data which is accurate and complete to the CMS iQIES system.This timeframe is required for the following assessments:
- Admission
- Annual
- Significant Change in Status
- Significant correction prior to full assessment
- Significant correction of prior quarterly assessment
- Quarterly review
- Items required upon a resident’s transfer/ reentry/ discharge or death (Entry and Death in Facility Tracking records, Discharge assessment)
The 14-day timeframe also applies to the provision of background information when there is an initial MDS transmission where the resident does not have an admission assessment.
For comprehensive assessments, this means the assessments are transmitted within 14 days of the Care Plan Completion Date (V0200C2 + 14 days). For all other assessments, the timeframe for submission is within 14 days of the MDS Completion Date (Z0500B + 14 days). Tracking record information must also be submitted within 14 days of the Event Date:
- Entry records (A1600 + 14 days)
- Death in Facility Records (A2000 + 14 days)
Regardless of how many “hats” your MDS staff are wearing, whoever is assigned the responsibility for ensuring that MDS data is encoded and submitted per defined timeframes needs to recognize the importance of the requirements. This can certainly be considered a “gotcha” deficiency as it can easily be avoided if a facility has a sound system in place for encoding and transmitting, including assigning a back-up staff member to complete this task when someone is on vacation. I am also saying that because, when I question a facility’s staff as to what happened when F640 is cited, I invariably hear that the MDS Coordinator was on vacation or out sick. You must have a system in place for encoding and transmitting MDS data that includes a contingency plan for an absent staff member.
Linda Elizaitis, President, CMS Compliance Group, Inc.