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New Surveyor Guidelines on MDS Coding Errors

On March 10, 2025, CMS and the Department of HHS released a revision to the LTC Surveyor Guidance (originally released on January 16, 2025) that will go into effect on April 28, 2025. 

This revision includes an update on the Accuracy of MDS Assessments (F641), which has been expanded to incorporate the former Coordination/Certification of Assessment (F642), now set for removal.

Surveyors are being instructed to report inaccurate MDS coding to the OIG instead of their CMS regional office and Medicare Fraud Control Unit if the following criteria are met:

  • A pattern (at least 3 residents) of the SAME inaccurate MDS coding by the staff who completed, signed, and certified to the accuracy of that MDS item (via signature in Z0400)
  • There are indications or concerns that the staff member(s) knew that the coding was inaccurate
  • The determination of “willfully and knowingly” is subjective and is left to the surveyor to decide

The Point Is:

Greater focus has been placed on the accuracy of MDS assessments. When assessments are accurate, quality of care, quality measures, and reimbursement follows. The new guidance does not prohibit modifying assessments—it emphasizes the facility’s responsibility to ensure documentation and capture of MDS data accurately reflects each resident during the look-back period.

The recent measures guiding surveyors to report inaccuracies to the OIG underscores the necessity of ensuring every MDS coordinator has the education, resources, and support needed to remain in compliance with the requirements for properly completing the MDS.

The guidelines within the MDS 3.0 RAI Manual should be followed at all times.

QRM has a team of clinical reimbursement specialists ready to support your MDS coordinators. Please let us know if we can be of help.

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