Revised Ftag of the Week – F641 Accuracy of Assessments (Pt. 1)

When we originally reviewed F641 Accuracy of Assessments on the CMSCG Blog back in November 2018, we were towards the start of surveyors getting their hands around the LTCSP, but F641 was in the National Top 10 at that time. Per CASPER data for 2024 (current as of March 16, 2025), F641 landed in the same spot nationally for nursing homes in 2024. In the first few months of 2025, using the same CASPER data, F641 remains at #9, with 17.2% of recertification surveys including this tag.

---

---

F641 has been receiving increasing amounts of attention in the past year or so, particularly around the validity of those Schizophrenia diagnoses, so it was no surprise that when the draft revised guidance to surveyors was released, it included revisions to F641 Accuracy of Assessments. Not only was F641 revised, F642 Coordination/Certification of Assessments, is being absorbed into this tag, so we’ll be losing yet another tag number – but not losing the regulatory requirements.

Goodbye F642 – Hello More F641

F642 Coordination/Certification of Assessment is another one of the regulations which we waited to review as part of our Ftag of the Week series, but we’ll take time to review it now. Specifically, the regulatory requirements which are current part of F642 which will be relocated to F641 include:

• A registered nurse must conduct or coordinate each assessment with the participation of appropriate health professionals.
• Each assessment must be signed and certified as completed by a registered nurse.

The third, existing regulatory requirement is one where we’ve been hearing feedback from MDS Coordinators that they are worried about. Requirement number three addresses penalty for falsification, namely:

• Any individual who willfully and knowingly certifies a material and false statement in a resident’s assessment is subject to a CMP of not more than $1000 per assessment
• Any individual who causes another individual to certify a material and false statement in a resident assessment is subject to a CMP of not more than $5000 per assessment
• Clinical disagreement would not be considered a material and false statement.

The Interpretive Guidance (IG) in the existing Appendix PP (8/2024) indicates that each individual assessor is responsible for certifying the accuracy of the responses provided during the assessment. The same guidance stating that backdating completion dates is not acceptable, but recording the actual date of completion would not be considered backdating.

The guidance related to the pattern of MDS assessments and submissions has also not changed but is being relocated from F642 to F641. Some important items from the IG in this area to be aware of:

• Willfully and knowingly providing false assessments may be indicative of payment fraud or attempts to avoid reporting negative quality measures.
• Details on several “patterns” of submitting are included in the IG to guide surveyors as to where there may be an issue. Note that surveyors are only expected to review the MDS for accuracy, not attempt to try to investigate potential falsification.

If surveyors are only looking at accuracy and not potential falsification, that means it’s not a big deal, right? Well, the existing guidance states that these issues should be reported by the State Agency to the CMS Regional Office and Medicaid Fraud Control Unit. The revised guidance, on the other hand, includes new investigative procedures guidance.

The revised IG states that if a surveyor identifies a pattern (defined as 3 or more residents) of inaccurate MDS coding by staff who completed, signed and certified the accuracy of the assessment they completed and there are concerns that this individual knew that the coding was inaccurate, a referral to the Office of the Inspector General (OIG) should be made. The OIG is expected to investigate the issue for falsification.

In Part 2 of our revised Ftag of the Week for F641, we’ll review more requirements and revisions to the guidance for surveyors. Remember – the revised guidance is effective April 28, 2025, so it’s time to finalize your P&P and review any practices which may create issues on your next survey. Not sure you’re ready or the next steps to take? Contact CMS Compliance Group, Inc. to discuss our onsite and remote-based consulting services for skilled nursing.