There are situations when a Skilled Nursing provider may complete an assessment after the 5-day assessment.  This assessment is an unscheduled assessment and when deemed appropriate by the provider, may be completed to capture changes in the resident’s status and condition.

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The optional Interim Payment Assessment (IPA) may be used any time between the 5-Day Assessment and the Part A Discharge Assessment. Providers can choose to complete an IPA Assessment to capture changes in resident characteristics. These changes in resident characteristics would be such that it actually affects the PDPM calculation in one or more of the five case-mix adjusted payment categories: Physical Therapy (PT), Occupational Therapy (OT), Speech-Language Pathology (SLP), Nursing, or the Non-Therapy Ancillaries (NTA). Capturing these changes will capture an increase payment, but more importantly, reflects the actual resident type you are caring for.

Ensure coding accuracy of the 5-day Assessment. This is extremely important. Consider the variable per diem rate for the PT, OT, and NTA components. For the NTA, payment will be three times higher for the first three days of the resident’s Part A stay.  If you do not accurately capture all active/current diagnoses on the 5-day MDS Assessment, you miss an opportunity to increase payment those first three days of the resident’s stay by three times. Remember, the IPA payment is effective the day of the IPA ARD until discharge or until another IPA is completed. The purpose of eliminating some PPS Assessments is to decrease provider burden. If inaccurate coding on the 5-day Assessment is present, and you want to do an IPA, you are adding additional burden to your team members.

Transition from RUG-IV to PDPM: Transitional IPA Required!

Residents skilled under the traditional Medicare Part A RUV-IV benefit and who will continued to be skilled under traditional Medicare Part A on October 1, 2019 will require a (transitional) IPA Assessment. The ARD must be set anytime between 10/1/19 -10/7/19.  Section GG will need to be completed on this (transitional) IPA Assessment and the look-back period is the IPA ARD and two days prior. This transition is the only exception to the IPA being optional.

The IPA is a:  → Standalone Assessment                    → Unscheduled PPS Assessment                  → Optional Assessment.

The IPA ARD (item A2300) may be set for any day of the SNF PPS stay, beyond the ARD of the 5-Day Assessment; the ARD for an IPA may not precede that of the 5-Day Assessment. The IPA Assessment must be completed (item Z0500B) within 14 days after the ARD (ARD + 14 days) and must be submitted electronically and accepted into the QIES ASAP system within 14 days after completion (item Z0500B) (completion + 14 days).

The ARD is determined by the provider and may not be combined with any other assessments (PPS or OBRA).

Assessment period for Section GG is the last three days (the ARD and two days prior). For Section GG on the IPA, providers will use the same 6-point scale and activity not attempted codes to complete the column “Interim Performance,” which will capture the interim functional performance of the resident.

The IPA authorizes/changes payment beginning on the IPA ARD and continues until the end of the Medicare Part A stay or until another IPA is completed. There is no limit to the number of IPAs that can be completed during the resident’s Part A stay. The IPA does not affect the variable per diem schedule.


Identifying Change

Providers may want to consider their effective ability to identify resident changes.  It is extremely important that all facility staff are able to identify when a resident isn’t “themselves”, or “acting differently”, or is “just off today”.  Communication is imperative when any facility staff member identifies changes in the resident.  Even if the resident isn’t themselves or is acting differently or is just off that particular day, report it immediately to the nurse.  The nurse should take the report seriously and never dismiss it as “that’s how they are sometimes” and document the change in the medical record.  We have to take resident changes seriously in order to effectively recognize clinical characteristics that could require more comprehensive care planning, change the component calculation of your resident, and in turn, potentially increase in payment through completion of an IPA.

Gina Tomcsik
Director of Compliance and Regulatory Strategy