To date, the accuracy of section GG (functional abilities and goals) hasn’t mattered from a payment perspective. Section GG doesn’t affect payment under the RUG-IV case-mix classification system, and the Skilled Nursing Facility Quality Reporting Program (SNF QRP) only penalizes providers financially for failing to meet the data submission threshold for required MDS data elements, including section GG items. In other words, completeness—not accuracy—is what allows providers to avoid the SNF QRP’s 2% payment cut every fiscal year.
As a result, many SNFs have relied exclusively on therapy to complete section GG, says Robin Hillier, CPA, STNA, LNHA, RAC-MT, president of RLH Consulting in Westerville, OH. “However, CMS always intended section GG to be a collaboration that includes both nursing’s perspective and therapy’s perspective. PDPM will require providers to make good on CMS’s intent because section GG will affect three of the five case-mix-adjusted PDPM payment components: nursing, physical therapy (PT), and occupational therapy (OT).”
To achieve this collaboration, directors of nursing services (DNSs) will need to ensure that their nurse assessment coordinators (NACs) take on a larger role in coordinating the collection of section GG data, advises Hillier. “NACs should look at section GG from the perspective of what the nurses are seeing on the floor, as well as what the therapists are seeing during the therapy evaluation. Then they can ensure that section GG is coded to reflect the usual performance over the first three days, and it doesn’t just capture what the therapists see during the evaluation.”
In addition, NACs will have to lead a similar collaborative process when the interdisciplinary team (IDT) decides to complete an Interim Payment Assessment (IPA) in order to collect interim (column 5) performance data for section GG, she points out.
When determining the roles of various IDT members, it’s important to remember that section G (functional status) will still be required on some assessments, says Hillier. Here’s a summary of which MDS item sets require or don’t require documentation for section G and/or section GG:
Section G vs. Section GG: Which MDS item sets require what
| Section G | Section GG | |
| Nursing Home PPS (NP) Item Set | Yes | Yes |
| Interim Payment Assessment (IPA) Item Set | No | Yes |
| Nursing Home Part A PPS Discharge (NPE) Item Set | No | Yes |
| Swing Bed PPS (SP) Item Set | Yes | Yes |
| Swing Bed Discharge (SD) Item Set | Yes | Yes |
| Optional State Assessment (OSA) Item Set | Yes | No |
| Nursing Home Comprehensive (NC) Item Set | Yes | Yes |
| Nursing Home Quarterly (NQ) Item Set | Yes | Yes |
| Nursing Home Discharge (ND) Item Set | Yes | Yes |
| Nursing Home and Swing Bed Tracking (NT/ST) Item Set | No | No |
Note: Some sections are longer on some item sets and shorter on others.
This chart is subject to change due to the draft status of the
currently available draft v1.17.0 item sets.
“In most facilities, nurse aides do the data collection for section G. However, section G is very different from section GG, so it doesn’t make sense to try to educate nurse aides to document for both sections,” Hillier points out. “The nursing assistants won’t be able to understand the distinction between the two sections, and documentation will be a mess.”
One option is for NACs to continue to code section G based on the nurse aide documentation but to obtain the documentation for section GG from nurses on the floor and then to collaborate with therapy, suggests Hillier. “Either the floor nurses or the NAC could talk to the aides as part of the information-gathering process to help them assess usual performance and document for section GG, but the aides shouldn’t have section GG documentation tools to complete in addition to their section G tools.”
One floor nurse whose job may sync up well with section GG is the restorative nurse, says Hillier. “Section GG only has to be completed for Part A residents, so it makes sense for the nursing information that is needed for section GG to be gathered by whichever nurse is responsible for restorative nursing. The restorative nurse should already be familiar with the types of activities that are coded in section GG, and they could do an assessment, including interviewing staff, residents, and families, within the three-day assessment window for the 5-day MDS and for any needed IPAs.”
Note: This option may not work in all facilities. The key is that DNSs cannot assume that the section G data collection process can simply be duplicated in section GG. To ensure accurate reimbursement under PDPM, it’s critical to have a discussion with the NAC and other IDT members to create a section GG data collection process that fits the facility and that brings in accurate, timely data for MDS coding.
Regardless of the process that facilities choose, section GG will impact a NAC’s workday, adds Hillier. “NACs will need to review all of the data available from the nursing perspective and the therapy perspective so that they can decide how to code section GG in accordance with the instructions in the RAI User’s Manual. Making sure that section GG is an accurate reflection of the resident’s usual performance over the three-day assessment window will take more time.”
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