AGING AND DISABILITY SERVICES ADMINISTRATION

October 30, 2001

AASA:? NH #2001-023

SUBJECT:?? MDS Restraint Coding Clarification

Dear Nursing Home/Facility Administrator:

The Centers for Medicare and Medicaid Services (CMS) has issued two questions and answers (Q&A) to clarify when a device is to be coded as a restraint on the minimum data set (MDS.)? Section P4 (Devices and Restraints) of the MDS, per the Resident Assessment Instrument (RAI) User?s Manual, is intended ?to record the frequency, over the past seven days, with which the resident was restrained by any of the devices listed below at any time during the day or night.?? Further clarification by CMS in the July 2001 Q&A document also reflects that the intent is to evaluate whether a device constitutes a restraint and, then, code only those devices listed in section P4 that have the effect of restraining the resident.

Question #123 from the August 1996 Q&A appears to be in conflict with the current clarifications and CMS is instructing providers to disregard this question and answer.? Providers are further directed to follow the intent and coding as identified in the RAI User?s Manual and the information from the July 2001 Q&A release.

This clarification represents a change from what has been taught in Washington State.? In the past coding was required to be done based on objective performance.? If a device was used, it was to be coded and the use explained in facility documentation, such as the resident assessment protocol (RAP.) Providers now will need to first determine if the device is a restraint and then code it per the RAI manual instructions.? This clarification in no way alleviates the provider from the responsibility to assess the need for a device and to assess the safety issues related to the use of a device.?

Note: There is no place on the MDS to code bed and/or chair alarms.? The use of these devices is to be assessed and documented, as above, but not coded in P4.

For complete information on the two new Q&A?s as well as the 8/96, 3/01 and 7/01 sets of questions and answers from CMS see the following web site: http://www.hcfa.gov/medicaid/mds20/.??

If you have questions or need further information, please contact Marjorie Ray, RN

Washington State RAI Coordinator, at (360) 725-2487 or e-mail rayma@dshs.wa.gov

Sincerely,

Patricia K. Lashway, Director

Residential Care Services

Enclosure