Published by SMK Medical Team | September 2025

The Centers for Medicare & Medicaid Services (CMS) has released the RAI User's Manual v1.20.1, introducing significant changes to the Minimum Data Set (MDS) effective October 1, 2025. These updates span multiple sections and require immediate attention from all SMK Medical facilities to ensure continued compliance, optimal reimbursement, and quality care delivery.

At SMK Medical, we're committed to helping our teams navigate these changes seamlessly. Here's your comprehensive guide to the most critical updates:

Section A: Administrative Refinements

Key Changes:

• Terminology Update: Item A0800 "Gender" has been replaced with A0810 "Sex" (coding remains unchanged)
• Transportation Assessment Overhaul: A1250 retired and replaced with A1255Lookback period standardized to 12 months (previously 6-12 months)
  Simplified coding combines all transportation services into one response
• New Requirement: Only mandatory for Medicare 5-day MDS when admission date is less than 366 days
• No longer required for End of Medicare Stay MDS (NPE)
  

SMK Medical Impact:

These changes reduce documentation burden while improving accuracy for SNF QRP reporting. Our facilities should update assessment protocols to reflect the new 12-month lookback period and ensure proper completion triggers are in place.

Section D: Mood Assessment Enhancement

Updated Guidelines:

• PHQ-2 to 9 Coding: Dashes only permitted when residents cannot provide frequency responses
• Completion Standard: Interviews with three or more blank/dashed frequency items are considered incomplete

SMK Medical Focus:

This tightening of depression screening protocols directly impacts SNF QRP compliance. Our clinical teams must ensure thorough completion of mood assessments to maintain quality reporting standards.

Section GG: Functional Abilities - Critical for PDPM

Major Updates:

• Helper Requirements: Two or more helpers = Code 01 Dependent
• Device Specifications: Therapy-only equipment (exoskeletons, parallel bars) excluded from coding
• Assessment Window: 3 calendar days maximum; minimize dash usage
• Specific Clarifications:Stair mobility may include scooting techniques
  Recliners used as beds qualify for transfer coding
  Footwear includes grip socks and any foot covering
  Walking assistance levels refined for accuracy
  

SMK Medical Priority:

Section GG directly drives PDPM reimbursement and case mix calculations. Our rehabilitation and nursing teams must master these clarifications to optimize both resident outcomes and facility reimbursement.

Section J: Falls and Injuries - Enhanced Precision

Updated Definitions:

• Fall Definition: Any unintentional change to lower surface, including external force
• Intercepted Falls: Still considered falls except during supervised therapy balance testing
• Injury Classifications:Standard Injuries: Now include skin tears, bruises, sprains, and pain complaints
  Major Injuries: Expanded to include fractures, dislocations, organ injuries, crush injuries
  
• Important: Pathological fractures (osteoporosis-related) are NOT coded as fall injuries

SMK Medical Compliance:

Fall reporting has direct implications for surveys, quality measures, and potential litigation. These clarifications demand consistent application across all SMK Medical facilities to ensure defensible documentation.

Section K: Nutrition and Weight Management

Standardization Updates:

• Weight loss/gain calculations now use only weights closest to evaluation timepoints
• When multiple weights exist, select the measurement nearest to the assessment date
• Enhanced visual examples provided for consistency

Additional Important Updates includes the following.

Section M - Skin Conditions:

New Present on Admission (POA) coding rules for ulcers transitioning between stageable and unstageable classifications.

Section N - Medications:

Enhanced high-risk medication coding with emphasis on consistent resource utilization and pharmacist collaboration. IV flushes for patent access are excluded from anticoagulant coding.

Section O - Special Treatments:

• O0390 Therapy Services replaces most O0400 items
• Simplified checkbox format for therapy ≥15 minutes/day
• O0400 now limited to respiratory therapy days only
• O0420 (therapy calendar days) eliminated

CMS Removed Section:

Section R (Social Determinants of Health) has been excluded from the final MDS version, streamlining the assessment process.

SMK Medical Implementation Strategy

Action Is Required to Remain Compliant:

1. Staff Training: Begin comprehensive training programs immediately
2. Documentation Updates: Revise all assessment protocols and forms
3. System Updates: Ensure EMR systems reflect new coding requirements
4. Quality Assurance: Implement additional review processes for Sections GG and J
5. Pharmacist Collaboration: Strengthen medication review processes

The Bottom Line for SMK Medical

These October 2025 MDS changes represent CMS's continued focus on precision, consistency, and outcome-based care. For SMK Medical facilities, the key priorities are:

• Section GG mastery for optimal PDPM reimbursement
• Section J precision for defensible fall and injury documentation
• Consistent application of all updates across our network

Your Next Step

October 1 isn’t a suggestion, it’s the law. Facilities that are unprepared will face survey citations, compliance risk, and revenue loss.

At SMK Medical, we don’t just educate—we protect your bottom line with:

• Mock Surveys – Walkthroughs that mirror the state process and uncover hidden risks. Facilities that receive citations often see their daily resident rates rise $50–$100 per patient.
• MDS Accuracy & Coding Audits – Pinpoint errors before they cost you.
• MDS Completion & Support – Experienced nurses with a 48-hour turnaround guarantee.
• Education & Training – Hands-on learning that builds staff confidence and compliance.

📞 Call us at 313-314-8267
📧 Email [email protected]om
 

For questions about implementation or additional training resources, contact the SMK Medical Compliance Team. Together, we'll ensure seamless transition to these new requirements while continuing to deliver exceptional care to our residents.