Software bugs during MDS kickoff could lead to ongoing revenue challenges for providers | Marcum LLP

You attended training, planned the implementation with your team, you thought you were ready. If you feel like you’re hitting roadblock after roadblock on October 1, you’re not alone.

Major EMR errors

Providers across the country expressed frustration over issues with electronic medical record (EMR) software vendors during the transition to the Minimum Data Set (MDS) 3.0 version 1.18.11. EMR errors were not specific to any particular vendor. The Centers for Medicare and Medicaid Services (CMS) has issued an errata document identifying twenty-one (21) issues in the MDS Resident Assessment Instrument (RAI) RAI Manual version 1.18.11. This caused a trickle-down effect, causing all EMR vendors to experience problems in one way or another. Some of the most concerning and common errors caused inaccurate codes for Resource Utilization Groups (RUGs). Providers faced a difficult decision; to delay submitting their MDS until system changes are made, or to submit MDSs with incorrect codes. When questioned by callers during a CMS Open Door Forum [10/12/2023], CMS discussed the consequences of not submitting an MDS: Claims submitted without an MDS submission will not be paid. CMS officials were unable to provide specific fixes for software bugs, or estimated timelines for correction; instead, providers should work directly with their suppliers, Medicare Administrative Contractors (MACs), or contact the Internet Quality Improvement & Evaluation System (iQIES) helpdesk.

To illustrate the extent and complexity of the errors providers encountered; Nearly a month after deploying MDS 3.0 version 1.18.11, one of the most prominent EMR software in the US continues to investigate unresolved bugs, in a multi-page document detailing the status of the fix. Other software vendors have asked users to submit IT tickets directly to their software vendors. Providers reported significant complications with multiple software vendors:

  • Health Insurance Prospective Payment System (HIPPS) scores were not calculated for OBRA assessments;
  • Incorrect HIPPS scores were calculated for MDS assessments for Medicare;
  • Erroneous transfer patterns resulted from both CMS technical errors and EMR technical errors;
  • Inability to submit MDS assessments; And
  • Software patches were issued afterwards, but were not updated consistently.

Timelines for correction may vary; unfortunately, providers are at the mercy of their EMR and even CMS to make corrections to identified errors. Facilities should contact their software vendor for a current list of known issues during the MDS transition. This produces a software-specific ‘map’ that providers can use until the software patches are fully updated. Additionally, it is recommended that providers continually monitor for errors in their EMR software as the industry continues to see issues arise. As facilities complete the first round of billing since 10/1/23 for October and November claims, experts expect this will cause new EMR issues.

Eye on revenue amid rolling EMR updates

With EMR error corrections at varying levels of resolution, providers should heed the warning: your revenue may be at risk due to inaccuracies reflected in your EMR. It is recommended that healthcare providers not take the Patient Driven Payment Model (PDPM) scores calculated within the EMR at face value during this transition period. In some circumstances, facilities have found that EMRs have not fully or completely calculated clinical reimbursement scores, leaving valuable dollars on the table. Providers should spend additional time at Triple Check claims meetings in October and November to verify the accuracy of the PDPM case mix components.

If an institution is inexperienced in calculating PDPM case mix groups, it may consider delaying MDS submission until EMR failures are fully corrected and PDPM scores are accurately calculated within the EMR. Delaying filing will not impact revenue, but will pose an issue with regulatory timeliness requirements. It is recommended that providers contact their state’s RAI coordinators to request a waiver for the timely submission of MDS due to multiple errors in completing and submitting MDS.

Consider working with an expert. Celtic Consulting, a post-acute consultancy, provides operational, clinical and financial support to healthcare providers. Our staff regularly works with SNFs to provide MDS assessments for accuracy prior to submission and billing. Contact Celtic today, let’s discuss how we can help your organization.

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