T

he spring of 2004 will bring not only the fresh spring flowers and budding trees but a fresh focus on Minimum Data Set (MDS) database accuracy with the use of the Data Assessment and Verification project (DAVe). DAVe is a focus by the Centers for Medicare and Medicaid Services (CMS) on the importance of the MDS database. Steve Pelovitz, director of the Survey and Certification Group at CMS, said, "With increasing reliance on the MDS data, CMS recognized the need to establish a centralized and coordinated data verification program. The main objective of the DAVe program is to assure the accuracy and consistency of MDS data. The goal of the program is to pay claims correctly: right amount, right provider, right service, right beneficiary."
       The launch of this data analysis program will impact overall facility operations and will focus all operations to:
* Review MDS data collection processes and procedures
* Identify the competencies of persons working with MDS data
* Identify standard policies and procedures all staff need to utilize for data collection
* Establish terminology and definitions for use by all staff
* Create orientation and training inservice programs connected to the MDS process
* Look at all databases created by MDS transmissions.
       Have we heard these words before? Yes, but now we must listen. The DAVe report, analysis, and selection process will drive the post-payment service process to which all Medicare and Medicaid facilities will be subject.
       The DAVe program will communicate the results of data analysis with Medicare, state survey agencies, Medicaid agencies, and other governmental state holders. The off-site review will precipitate on-site reviews to verify the accuracy of the MDS and identify payment and health safety vulnerabilities.
       Facilities that have not reviewed their data collection procedures need to begin an analysis of the data collection process that feeds the MDS database for the facility. Who collects the data? What definitions are utilized by the staff to identify and describe various data items? The universal use of the revised MDS 2.0 manual is essential throughout the facility. The use of audits and cross checks before data is recorded and transmitted is essential.
       Each facility must have an exact process for setting the assessment reference period and comprehensive data collection procedures for staff to follow. The completed MDS needs to be transmitted, verified, and recorded properly. Correction procedures must be carefully followed, and limited options for scoring need to be procedurized so all documents are handled the same. These are all operational responsibilities.
       The retrospective medical record review has off-site and on-site components. A review team will have professionals and access to technical experts (TEP) as they review the records.
       Some of the questions they will ask facilities are:
* How does the team get their information on how to complete the MDS?
* From where do they get their education to complete the MDS?
* How often is the knowledge base of the team updated?
* How do they get updated information or changes to the MDS process?
* What definitions are used in the facility for clinical or behavioral issues? Do they compare to the MDS manual?
       The DAVe pilot reviews have identified a number of issues. Off-site reviews identified discrepancies in MDS sections P and O as most common. The on-site review found more issues with section G. Three items were identified with discrepancies in all 3 reviews:
       01--Number of medications
       P-7--Physician visits
       P-8--Physician orders
       The on-site reviews include record review and observations of the resident. This is problematic for facilities with poor documentation processes connecting the clinical record to the MDS assessment.
       Then we have the Paired Assessment Accuracy Reports (PAARs) prepared as facility-specific data reports focused on predetermined trigger conditions. The reports will focus on potential coding problems. The first two trigger conditions identified at this point are pneumonia, MDS item I2e, and bladder incontinence, MDS item H1b.
       The overall focus of DAVe has been explained as three activities:
* Analyzing patterns and trends related to skilled nursing facility care
* Supporting the operational activities of the project (sample selection)
* Evaluating the results of the DAVe project.
       We have more to learn, questions to ask, and processes to understand related to this project. For now, we need to look inside operations to identify a consistent, accurate data collection process, following the current rules, performed by the competent professionals that establish the facility database. This is an administrative responsibility supported by nursing. I invite you to read federal tag 272.
       The Alliance Training Center offers training and continuing education programs related to this topic and other data and documentation issues. The MDS Review and Competency program is also offered to interdisciplinary audiences and associations.