DOH and OMIG Update on Initial MDS Audit Results
DOH and OMIG recently updated LeadingAge NY and other associations on the MDS audit process. OMIG outlined their observations based on the 79 audits they have completed. DOH laid out their intended time line for making rate changes and the schedule for auditing MDS submissions cycles subsequent to January 2012. The 79 homes already audited represent the initial group of the 305 homes whose January 2012 roster submission related MDS assessments will be audited due to case mix increases exceeding five percent. These are the highlights of the meeting:
Decisions regarding payment have not yet made. DOH expects to receive the data regarding any RUG re-categorizations from these 79 completed audits from OMIG by the end of May. At that time DOH will recalculate Medicaid rates for these homes to examine the financial impact of these re-categorizations and make a decision on whether to release final 7/1/12 rates reflecting the full value of reported CMI changes. Although the audit process seems to have found few issues with major financial impact, DOH is concerned about a large increase in the number of Medicaid residents in the rehabilitation categories that is accompanied by a similar decrease in Medicaid residents in the reduced physical function categories. OMIG is currently contacting the 79 homes that have been audited to offer them the option of a final exit conference by phone.
The next rate update is likely to be made in June. Once DOH receives the data from OMIG and decides how to proceed, department staff believes that rate sheets can be updated and issued within several weeks. However, that means that any payments stemming from this update are not likely to be released at least until July. Additionally, DOH made it clear that they intend to make only negative audit-based rate adjustments, a reversal of their previous statement that both under-coding and over-coding errors would be reflected in the adjustments.
Audits of homes with growth exceeding five percent will continue. OMIG will continue to audit the rest of the homes whose CMI increased by five percent or more from Jan. 2011 to Jan. 2012. DOH has now compiled the July 2012 roster submission data and is deciding where to focus auditing resources based on that submission. The statewide growth in Medicaid CMI from Jan. 2012 to July 2012 is roughly three percent. DOH is exploring the possibility of combining multiple submissions into a single audit and possibly contracting with IPRO with the goal of completing audits of MDS assessment related to Jan. 2012 and July 2012 roster submissions by the end of March 2014. The state hopes to establish a six month audit cycle starting with 2013 roster submissions.
The majority of OMIG findings involved Section G ADLs. Auditors noted that failure to follow the “rule of 3” resulted in assigning both higher and lower RUGs than warranted. Other audit findings included incorrect therapy minutes; missing qualifiers of proof of physical exams; missing qualifiers or proof of physician order changes; and RUG determining items that were not supported during the look back period.
We will continue working with DOH to help address their concerns regarding the assessment trends and will let you know as soon as more information is available.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841