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).”