The table below contains the "crosswalk" linking the original recommendation text (Column 2) as adopted by the SACRR, to the recommendation as it exists in its final form (Column 4). The SACRR instructed its staff to edit the originally approved recommendation text for clarity and uniformity, and elimination of redundancy. The SACRR reaffirmed its adoption of the recommendations, as modified in the Final Master List. As such, we have included the recommendation’s original numbering (Column 1) as well as the numbering used for the Final Master List (Column 3). Column 5 includes the reason for any change(s), where applicable. Those seeking additional information should e-mail the Regulatory Reform staff at regreform@hhs.gov.

Original #

Original Recommendation

Final #   

Final Recommendation

Reason for Change

1

Immediate: Take action necessary to publish a final rule on the previously proposed rule (i.e. Conditions of Participation (CoPs) for Home Health Agencies (HHA) currently in the queue.

1

Publish a final rule on the previously proposed rule on Conditions of Participation (COPs) for home health agencies (HHAs) currently in the queue.

Clarification.

2

Short-Term Proposal: Announce removal of the HHA CoP Proposed Rules from the docket if it remains dormant for more than 6 months.

2

Announce removal of the Proposed Rules on HHA COPs from the docket if the proposed rule remains dormant for more than six months from the date of adopting this recommendation.

Clarification.

3

Immediate: Eliminate or modify Medicare’s Home Health Agency Branch Office and Sub-Unit definitions to reflect current technology and accepted practices.

3

Eliminate or modify the definitions of branch office and sub-unit contained within Medicare’s COPs for HHAs to reflect current technology and accepted practices.

Clarification.

4

Immediate: Allow M+COs to access State and county codes and input changes to that data element this summer. Direct access to proprietary information held in Federal databases would be limited in accordance with the Privacy Act.

4

Allow Medicare+Choice Organizations (M+COs) to access State and county codes and input changes to that data element during the summer of 2002 for payment reconciliation of special status Medicare enrollees. (Direct access to proprietary information held in Federal databases would be limited in accordance with the Privacy Act.)

Clarification.

5

Intermediate reform: Determine new procedure for processing working aged enrollments and establish pilot. Analyze systems’ issues with ESRD enrollments and propose workarounds.

5

Determine new procedures for processing working aged enrollments for M+CO payment reconciliation purposes and establish pilot. Analyze systems issues with ESRD enrollments and propose workarounds.

Clarification.

6

Immediate: Begin simplifying the ACRP filing process by examining the following options and prepare a report due 9/30/02 containing recommendations regarding:

(f) Reducing the number of benefit categories submitted in the ACR for the 2004 filings.

6

Clarification.

7

Immediate: Based on consultation obtained from industry experts, provide additional comprehensive training for auditors concerning the development of ACR proposals, in order to decrease the occurrence of erroneous and incorrect findings; include industry experts in the faculty for the training sessions

7

Provide additional comprehensive training for auditors concerning the development of ACR proposals in order to decrease the occurrence of erroneous and incorrect findings; include industry experts in the faculty for the training sessions. Consult with industry experts in the design of the training.

Clarification.

8

Immediate: Convene a work group to continue to pursue alternative methods of determining compliance with regulations, including those areas where the M+CO’s compliance plan meets CMS standards. Plans with good performance should not be subject to total review.

8

Convene a work group whose goal is to pursue alternative methods of determining a M+COs compliance with Medicare’s regulations, such as by data-driven and "focused review"-based, biennial monitoring visits. (Plans with good performance should not be subject to total review.) Implement work group’s recommendations no later than January 1, 2004.

Consolidation of similar
recommendations.

9

Intermediate: Work group recommendations should be approved by 6/1/03 for implementation 1/1/04.

8

Convene a work group whose goal is to pursue alternative methods of determining a M+COs compliance with Medicare’s regulations, such as by data-driven and "focused review"-based, biennial monitoring visits. (Plans with good performance should not be subject to total review.) Implement work group’s recommendations no later than January 1, 2004.

Consolidation of similar
recommendations.

10

Immediate: Continue to standardize and streamline the marketing review process, including nationwide use of "use & file" standards, and intermediately, establish uniform performance standards for all ROs, and conduct CO/RO/M+CO training regarding standards for review that do not exceed statutory standards.

9

Continue to standardize and streamline the process of reviewing M+CO marketing materials, including nationwide use of "use & file" standards; establish uniform performance standards that do not exceed statutory requirements and provide training prior to their use by all CMS Regional Offices (ROs).

Clarification.

11

Immediate: Establish a policy wherein joint training is conducted for M+CO, RO and CO staff regarding major CMS initiatives and issuance of significant changes in existing policy.

10

Establish a policy wherein joint training is conducted for M+CO CMS Regional Office (RO) and Central Office (CO) staff in one setting regarding major initiatives and issuance of significant changes in existing M+C policy.

Clarification.

12

Intermediate: Establish a policy to provide sufficient notice to M+COs to implement major systems’ changes allowing M+COs to adequately budget for said changes. CMS establishes policies that often require plans to change their systems on short notice resulting in unbudgeted and hectic "fire drills," many of which occur when M+COs are in the midst of implementing other statutory system upgrades such as Y2K and HIPAA.

11

Establish a policy to provide sufficient notice to M+COs to implement major CMS information systems’ changes allowing M+COs to adequately budget for said changes, many of which occur when M+COs are in the midst of implementing other statutory system upgrades, such as Year 2000 and HIPAA.

Clarification.

13

Immediate: Establish a Special Election Period (SEP) for current M+CO members who wish to enroll in a zero-premium plan offered by the same M+CO in 2002.

12

Establish a Special Election Period (SEP) for current M+CO members who wish to enroll in a zero-premium plan offered by the same M+CO in 2002 consistent with the "lock-in" requirement.

Clarification.

14

Immediate: Establish a policy that allows M+C plans to default members to replacement plans based on the member’s primary care physician choice.

13

Establish a policy that allows M+C plans to default members to replacement plans based on the member’s primary care physician choice.

Clarification.

15

Immediate: Review and revise the language of its template on Medicare Health Plan Compare in situations where there is a $0 premium or $0 co-pay. The fill-in-the-blank default template language does not make sense for situations where the dollar amount is greater than $0. The result is confusing, misleading and possibly contradictory language as to financial liability.

14

Review and revise the language of its template on Medicare Health Plan Compare in situations where there is a $0 premium or $0 co-pay. The fill-in-the-blank default template language does not make sense for situations where the dollar amount is greater than $0. The result is confusing, misleading, and possibly contradictory language as to financial liability.

Clarification.

16

Immediate: CMS should clarify the 36-month rule to ensure that the 36-month window runs from the time an M+CO submits its information or claim rather than the time CMS acts on and enters the information or claim into the system.

15

Clarify the 36-month payment reconciliation rule to ensure that the 36-month window runs from the time an M+CO submits its information or claim rather than the time CMS acts on and enters the information or claim into the system.

Clarification.

17

Proposal: Finalize and publish the newest revision of the Technical Guide for states.

16

Publish regulations in a timely fashion. States are left in limbo or held financially responsible for unclear policies. (For example, finalize and publish the newest revision of Medicaid and School Health: A Technical Guide for States; clarify the policy related to payment for these services. [The "old" version of the Technical Guide still references Medicaid as a payer of last resort for health-related services. The transmittal of May 2000 indicates the opposite.])

Consolidation of similar
recommendations.

18

Immediate: Clarify the policy related to payment for these services. "Old" version still references Medicaid as payer of last resort for health related services. Transmittal of May 2000 indicates the opposite.

16

Publish regulations in a timely fashion. States are left in limbo or held financially responsible for unclear policies. (For example, finalize and publish the newest revision of Medicaid and School Health: A Technical Guide for States; clarify the policy related to payment for these services. [The "old" version of the Technical Guide still references Medicaid as a payer of last resort for health-related services. The transmittal of May 2000 indicates the opposite.])

Clarification.

19

Modify the definition of "hospital property" to be only the Emergency Department and any facility that holds itself out to the public as being available to provide emergency or urgent care, and the immediate vicinity (such as the hospital lawn, parking lot, waiting room, or similar location) in situations where someone seeking emergency care is physically unable to proceed to the actual emergency department or urgent care facility.

17

Modify the definition of "hospital property" to be only the emergency department and any other health facility that holds itself out to the public as being available to provide emergency or urgent care, as well as the "immediate vicinity" to the hospital property (such as the hospital lawn, parking lot, waiting room, or similar location) in situations where someone seeking emergency care is physically unable to proceed to the actual emergency department or urgent care facility.

Clarification.

20

Provide immediate guidance that use of community based EMS protocols, including established 911 protocols, is not a violation of EMTALA

18

Issue immediate interpretive guidance that use of community-based Emergency Medical Service (EMS) protocols, including established 911 protocols, is not a violation of the Emergency Medical Treatment and Active Labor Act (EMTALA).

Clarification.

21

Exclude from EMTALA patients who are referred to the Emergency Department for diagnostic or scheduled therapeutic services, unless the diagnosis is part of the EMTALA-required screening or the treatment is part of the EMTALA-required stabilization.

19

Exclude from the purview of EMTALA patients who are referred to the emergency department for diagnostic or scheduled therapeutic services, unless the diagnosis is part of the EMTALA-required screening or the treatment is part of the EMTALA-required stabilization.

Clarification.

22

Eliminate requirement for ABNs to be provided in the Emergency Room. Provide guidance that in the event of disaster or conventional attack involving multiple casualties and where hospitals use an established disaster plan, EMTALA does not apply.

21

Consolidation of similar
recommendations.

23

Provide guidance that in the event of bioterrorism, or the threat of bioterrorism, EMTALA does not apply to those hospitals directly affected and where hospitals follow a community based, regional or CDC directed protocol (especially for highly contagious outbreaks like small pox).

21

Clarification.

24

Review, update, and clarify in the Preamble to the Rule as well as in the Interpretive Guidelines what is mandated by EMTALA for the physician, separate from what is the hospital’s and the physician medical staff’s responsibilities. This should cover the issues already outlined as well as provide an explanation as to whether there is a recommended threshold for the application of EMTALA as it relates to the number of specialists and type of specialists on staff who are available to be "on-call" at a particular hospital; and identifies safe harbors when physician specialists who are in short supply are on call at more than one hospital at the same time, which is another instance where local EMS policies may preempt EMTALA.

22

Review, update, and clarify in regulation and interpretive guidance what is mandated by EMTALA for the physician; clearly distinguish physician medical staff responsibilities from hospital responsibilities. In particular, Centers for Medicare & Medicaid Services (CMS) guidance should provide an explanation as to whether there is a recommended threshold for the application of EMTALA as it relates to the number of specialists and type of specialists on staff who are available to be "on-call" at a particular hospital (e.g., identify safe harbors when physician specialists who are in short supply are "on-call" at more than one hospital at the same time).

Clarification.

25

Notify hospitals when EMTALA investigations are completed, regardless of the outcome.

23

Require that hospitals be notified when EMTALA investigations are completed, regardless of the outcome.

Clarification.

26

Modify enforcement practices by making PRO review mandatory early in the process and improving training of regional offices and state agencies to improve performance and consistency of review of complaints. The CMS Atlanta Regional Office procedures should be used as a model.

24

Make Quality Improvement Organization (QIO) review mandatory early in the process and improve training of regional offices and State Agencies to improve performance and consistency of review of complaints. (CMS’ Atlanta Regional Office procedures should be used as a model.)

Clarification.

27

Create an Emergency Services Cooperative Project that would follow the format of the Diabetes and Cardiovascular Quality Improvement Project. This should be developed and implemented with a scientific and technical advisory board of emergency physicians, first responders, emergency transportation specialists, consumers and other advisers. This group should also guide development of future regulations that would assure availability of effective emergency services in all parts of the country. This group would include on-call physicians (medical and surgical specialists who provide care for emergencies) as part of the scientific and technical advisory board for the Emergency Services Cooperative Project. In the future this group should take on thorny issues such as reimbursement mechanisms for EMTALA related services when patients don't have insurance.

132

Create an Emergency Services Cooperative Project that would follow the format of the Diabetes and Cardiovascular Quality Improvement Project. This should be developed and implemented with a scientific and technical advisory board of emergency physicians, hospitals, first responders, emergency transportation specialists, consumers and other advisers. This group should also guide development of future regulations that would assure availability of effective emergency services in all parts of the country. This group would include on-call physicians (medical and surgical specialists who provide care for emergencies) as part of the scientific and technical advisory board for the Emergency Services Cooperative Project. In the future, this group should take on thorny issues such as reimbursement mechanisms for EMTALA-related services when patients don’t have insurance; foster appropriate consultation with and involvement by QIOs; appropriate due process for hospitals and health care professionals before CMS can issue a public notice of termination and proceed with a termination letter.

Clarification.

28

Develop, fund and implement a comprehensive, ongoing communications plan that will be coordinated among HHS, CMS and its contractors, as recommended by the Advisory Panel on Medicare Education, to aggressively reach specific segments of the audience, using the appropriate channels including radio, TV, 1-800-MEDICARE, web and print media, as well as other strategies supported by research results.

25

Develop, fund and implement a comprehensive, ongoing communications plan that will be coordinated among HHS, CMS and its contractors, as recommended by the Advisory Panel on Medicare Education, to aggressively reach specific segments of the audience, using the appropriate channels including radio, TV, 1-800-MEDICARE, web and print media, as well as other strategies supported by research results.

No changes.

29

Improve efforts to educate elderly and /or disabled individuals approaching Medicare eligibility.

26

Continuously improve efforts to educate elderly individuals and/or individuals with disabilities approaching Medicare eligibility.

Clarification.

30

Add the 1-800 MEDICARE phone number and website address to the beneficiary’s Medicare card.

27

Add the 1-800 MEDICARE phone number and website address to the beneficiary’s Medicare card.

No changes.

31

Eliminate overly burdensome Medicare Secondary Payer requirements.

28

Eliminate overly burdensome Medicare Secondary Payer requirements.

No changes.

32

Research, consumer-test and evaluate the current MSN and incorporate those enhancements that result in improved beneficiary understanding of the content. Incorporate reasons for noncoverage or denial of service on MSNs in plain language and refer beneficiaries to relevant regulations regarding the noncoverage or denial.

29

Research, consumer-test, and evaluate the current Medicare Summary Notice (MSN) and incorporate those enhancements that result in improved beneficiary understanding of the content. Incorporate reasons for noncoverage or denial of service on MSNs in plain language and refer beneficiaries to relevant regulations regarding the noncoverage or denial.

No changes.

33

Improve and consistently update the Medicare Plan Finder (which includes original Medicare and Medicare + Choice).

30

Improve and consistently update the Medicare Plan Finder (which includes original Medicare and Medicare+Choice).

No changes.

34

Develop/implement performance standards for education and communication efforts that can be implemented consistently by CMS and by all its agents and partners.

31

Develop/implement performance standards for CMS’program of beneficiary education and communication efforts so that the program can be implemented consistently by CMS and all its agents and partners.

Clarification.

35

Refine the timeframes for MDS assessments so that payment and quality cycles coincide and such cycles require the least number of assessments in short periods of time.

44

Consolidate the number and timing of all MDS assessments to those that are required for care planning purposes, to the maximum extent possible. Refine the time frames for MDS assessments so that payment and quality cycles coincide and such cycles require the least number of assessments during short periods of time.

Consolidation of similar
recommendations.

36

To the maximum extent possible, develop shorter versions of the MDS (e.g., one of the quarterly assessments forms) for Medicare and Medicaid resident assessment. As part of this streamlining process, define the specific uses of any data elements prior to retaining any element on the form. Delete or revise all MDS data elements whose reliability is below generally accepted statistical standards.

32

Develop shorter versions of the Minimum Data Set (MDS) (e.g., one of the quarterly assessments forms) for Medicare and Medicaid resident assessment, to the maximum extent possible. Define the specific uses of any data elements prior to retaining any element on the form as part of an overall streamlining process. Delete or revise all MDS data elements whose reliability is below generally accepted statistical standards.

Clarification.

37

Clarify with interpretive guidance that MDS is a source document and does not require supporting documentation to justify coded responses.

33

Clarify with interpretive guidance that the MDS is a source document and does not require supporting documentation to justify coded responses.

No changes.

38

Automate the RAPs process at the facility level to free-up more time to meet patient care needs.

34

Automate the Resident Assessment Protocols (RAPs) process at the facility level to free up more time to meet patient care needs.

No changes.

39

Update the Coverage Manual relevant to Medicare Part A; e.g., who can be covered, authorized benefit periods, breaking the spell of illness and other administrative issues.

35

Update the Coverage Manual relevant to Medicare Part A (e.g., who can be covered, authorized benefit periods, breaking the spell of illness, and other administrative issues).

No changes.

40

Integrate updates of the MDS Manual and Resident Assessment User Guide and documentation into one manual, and keep the one manual up-to-date. Revise the current manual to incorporate all interpretive guidance and answers to frequently asked questions. Keep a downloadable, up-to-date manual available on the CMS website and make an annual print edition available each year which incorporates all life-to-date regulation and guidance with date certain. Publish any interpretive guidance as a quarterly addendum to the annual edition of the manual.

36

Integrate updates of the MDS Manual and Resident Assessment (RAI) User Guide and documentation into one manual, distribute the updated guide as soon as possible, and keep the one manual up-to-date. Revise the current manual to incorporate all interpretive guidance and answers to frequently asked questions. Keep a downloadable, up-to-date manual available on the CMS website and publish an annual print edition each year on a set date which incorporates all life-to-date regulation and guidance. Post quarterly updates on interpretive guidance to the CMS website.

Consolidation of similar
recommendations.

41

Continue to develop the MDS 3.0 which will include an analysis of the clinical relevancy of its contents and the capability to capture short stay assessment data, with an expected release date of 2004.

37

Continue to develop the MDS 3.0, which will include an analysis of the clinical relevancy of its contents and the capability to capture short stay assessment data, with an expected release date of 2004.

No changes.

42

Work with scientific and technical advisory panels, which include provider representatives, to continuously improve the RAI process. In addition, the advisory panels should be involved in the development and use of quality measures.

38

Adopt a continuous quality improvement process to keep the MDS tool and the RAI process current with medical practice and changing delivery systems. Establish a scientific and technical advisory panel to guide MDS use (measure work-ups, interpretation of data quality, and interpretation of results, quality reporting, assessment of need for new measures).

Clarification.

43

Allow a provider to have joint property rights of any data it submitted as part of the MDS process. This will allow the provider to access backup copies and may reduce the need for providers to warehouse redundant manual versions of the data.

39

Give providers joint property rights to any data submitted as part of the MDS process. (This will allow the provider to access backup copies and may reduce the need for providers to warehouse redundant manual versions of the data.)

Clarification.

44

Develop facility-specific analytic reports that allow facilities to compare their own performance in relation to local, regional and national trends. Develop reports and other tools to share aggregate data with all persons.

40

Develop facility-specific analytic reports that allow facilities to compare their own performance in relation to local, regional and national trends. Develop reports and other tools to share aggregate data with all persons.

No changes.

45

Shorten the interval from when MDS data were originally collected to when the reports of those data are made public. The older the data are, the less relevant the application and inferences to be drawn from those data.

41

Shorten the interval from when MDS data were originally collected to when the reports of those data are made public. The older the data are, the less relevant the application and inferences to be drawn from those data.

No changes.

46

Enhance CMS’s investment in education related to the use of MDS, including web-based training tools such as the Medicare Learning Network. Update the SNF section of the Medicare Learning Network to include a detailed tutorial on MDS.

42

Enhance CMS’ investment in education related to the use of the Minimum Data Set (MDS), including web-based training tools, such as the Medicare Learning Network. Update the skilled nursing facility (SNF) section of the Medicare Learning Network to include a detailed tutorial on MDS.

No changes.

47

For those Resident Assessments performed solely for the purpose of complying with Medicare payment requirements, eliminate data elements that are not used for payment or quality measurement. The Committee understands that a new, abbreviated MDS is currently being made available for PPS only assessments performed on or after July 1, 2002.

43

Eliminate data elements that are not used for payment, quality measurement, or survey purposes for those resident assessments performed solely for the purpose of complying with Medicare payment requirements.

48

To the maximum extent possible, consolidate the number and timing of all MDS assessments to those that are required for care planning purposes. See separate issue statement: "Consolidating and Abbreviating the MDS".

44

Consolidate the number and timing of all MDS assessments to those that are required for care planning purposes, to the maximum extent possible. Refine the time frames for MDS assessments so that payment and quality cycles coincide and such cycles require the least number of assessments during short periods of time.

Consolidation of similar
recommendations.

49

Add case mix / risk adjustment to quality indicators, as appropriate.

45

Add case mix/risk adjustment to quality indicators, as appropriate.

No changes.

50

In respect to the Nursing Home Compare website, improve the legend of key terms to accurately portray the facility’s data.

46

Improve the legend of key terms on the Nursing Home Compare website.

Clarification.

51

Focus on further automation of the MDS process, including the design of publicly available software with "interview wizards" and other intuitive data accumulation methods.

47

Further automate the Minimum Data Set (MDS) process, including the design of publicly available software with "interview wizards" and other intuitive data accumulation methods.

Clarification.

52

Improve the balance of comparative data available for the public, to include both quality of life and quality of care measures.

48

Improve the balance of nursing home comparative data available for the public to include both quality of life and quality of care measures.

Clarification.

53

Standardize the investigative protocols of HHS and state survey teams. The Committee feels that here is considerably more training needed for state survey teams. This training should focus on the proper interpretation of the regulatory compliance requirements placed on nursing facilities.

49

Standardize the investigative protocols of HHS and State survey teams. Increase training for State survey teams. Focus training on the proper interpretation of the regulatory compliance requirements placed on nursing facilities.

Clarification.

54

Use the HIPAA mandate as the basis to standardize terminology and identify common data elements used by payers, programs, providers and suppliers of care; and to determine whether RAPs are confidential and if any access protections are needed.

50

Use the Health Insurance Portability and Accountability Act (HIPAA) mandate as the basis to standardize terminology and identify common data elements used by payers, programs, providers, and suppliers of care and to determine whether the Resident Assessment Protocols (RAPs) are confidential and if any access protections are needed.

No changes.

55

Develop a standard instrument for the assessment of the health and functional status of patients receiving post acute services; to the extent feasible, integrate communication standards adopted under the Consolidated Health Information (CHI) eGov initiative as part of the development of this tool.

51

Develop a standard instrument for the assessment of the health and functional status of patients receiving post acute services as mandated by the Benefit Improvement and Protection Act (BIPA); integrate, to the extent feasible, communication standards adopted under the Consolidated Health Information (CHI) eGov initiative as part of the development of this tool.

Clarification.

56

CMS Provider Relations staff should seek greater partnerships and outreach to the full continuum of academic medical, nursing, and other allied health care training programs in order to expose all health care professionals (not just specialists) to the value of training in gerontology and participation in interdisciplinary teams, and to the utility of clinical patient care data sets in the process of care planning.

52

Seek greater partnerships and outreach to the full continuum of academic medical, nursing, and other allied health care training programs in order to expose all health care professionals (not just specialists) to the value of training in gerontology and participation in interdisciplinary teams, and to the utility of clinical patient care data sets in the process of care planning.

Clarification.

57

Establish an appeal process for default payments with a specified timeframe for the appeal.

Establish an appeal process for default Resource Utilization Group (RUG) payments with a specified time frame for the appeal. Establish clear and reasonable rules concerning submission of the MDS instrument so that providers are not penalized with default RUG payments for legitimate, minor delays in completing an MDS assessment.

Consolidation of similar
recommendations.

58

CMS must put in writing that the MDS is a source document and does not require supporting documentation to justify coded responses.

33

Clarify with interpretive guidance that the MDS is a source document and does not require supporting documentation to justify coded responses.

Consolidation of similar
recommendations.

59

CMS to issue a memorandum that clearly defines the MDS as a "source document."

33

Clarify with interpretive guidance that the MDS is a source document and does not require supporting documentation to justify coded responses.

Consolidation of similar
recommendations.

60

CMS should distribute the updated RAI User’s Guide as soon as possible.

36

Integrate updates of the MDS Manual and Resident Assessment (RAI) User Guide and documentation into one manual, distribute the updated guide as soon as possible, and keep the one manual up-to-date. Revise the current manual to incorporate all interpretive guidance and answers to frequently asked questions. Keep a downloadable, up-to-date manual available on the CMS website and publish an annual print edition each year on a set date which incorporates all life-to-date regulation and guidance. Post quarterly updates on interpretive guidance to the CMS website.

Consolidation of similar
recommendations.

61

Expand the time for completion of the OASIS instrument, for example from 5 days to 7 days to better reflect operations of HHAs.

54

Consolidation of similar
recommendations.

62

Change the lock-in time for the OASIS instrument, for example, from 7 days to 14 days to better reflect actual HHA operations. HHA nurses, especially in rural areas, only come to the HHA central office once a week.

54

Consolidation of similar
recommendations.

63

Delete elements that are duplicative or not used for payment, quality management, or survey purposes. CMS should particularly scrutinize elements listed in Miami testimony including MO190, MO340, MO640-680, MO780.

59

Consolidation of similar
recommendations.

64

Eliminate separate form for significant change in condition when it occurs in the 5 day window of the follow up assessment.

55

Eliminate separate form for significant change in condition when it occurs in the 5-day window of the follow-up assessment.

No changes.

65

Delete elements that are duplicative or not used for payment, quality management, or survey purposes. CMS should particularly scrutinize elements listed in Miami testimony including MO190, MO340, MO640-680, MO780.

59

Consolidation of similar
recommendations.

66

Create the option to use one form for all situations of care or change in status.

56

Create the option to use one OASIS form for all situations of care or change in status.

Clarification.

67

Share risk-adjustment methodology with all users – put on website.

57

Share OASIS risk-adjustment methodology with all users; make the information available on the CMS website.

Clarification.