The message was clear: QRP compliance is not just a regulatory requirement; it directly impacts reimbursement.
In a recent edition of Ask Amanda, we discussed the 2% Annual Payment Update (APU) penalty impacting over 2,000 skilled nursing facilities and the financial consequences of falling below the SNF QRP reporting threshold. The message was clear: QRP compliance is not just a regulatory requirement; it directly impacts reimbursement.
The prior discussion focused on the financial risk of the 2% APU reduction. The next step is understanding how facilities prevent that risk in daily operations. Dash prevention is not a task completed at the end of the MDS process. It is the result of timely assessments, clear interdisciplinary accountability, routine monitoring, and leadership oversight before the assessment is closed and submitted.
The most common question I hear from SNF leaders and MDS teams is, “How do we prevent dashes before they impact our QRP compliance?” The answer begins with changing how we view a dash.
A dash on the MDS does not simply mean a box was left blank. It may indicate that an assessment was not completed, information was unavailable, or the item was not completed according to MDS coding requirements. More importantly, a dash often reveals a breakdown in communication, documentation, or interdisciplinary processes.
Prevention Starts Before the MDS Is Closed
The strongest MDS teams do not wait until the final validation report to identify missing information. Preventing dashes requires a proactive process beginning at admission and continuing throughout the resident’s stay. Common high-risk QRP areas include:
• Resident interviews, including BIMS, PHQ, and pain assessments
• Section GG functional assessments
• Standardized Patient Assessment Data Elements (SPADEs), including applicable SDOH-related items such as health literacy, transportation, and social isolation
• Height and weight documentation
• COVID-19 vaccination information
In day-to-day operations, dashes often occur when:
• BIMS, PHQ, or pain interviews are not completed timely because the resident discharged before the interview was attempted
• Responsibility for completing or communicating interview results is unclear
• Section GG usual performance is not reviewed with the interdisciplinary team before the assessment is closed
• Height or weight documentation is incomplete or unavailable during the assessment window
• Vaccination information is not verified before submission
• Dash trends are reviewed after the deadline instead of during the correction window
One of the biggest misconceptions in skilled nursing is that avoiding MDS dashes is solely the responsibility of the MDS Coordinator. The MDS Coordinator serves as the editor-in-chief of the resident’s story, ensuring the information is complete, accurate, and supported. However, the entire interdisciplinary team writes the story through their assessments, observations, communication, and documentation.
Nursing must complete timely assessments and communicate clinical changes. Therapy contributes timely evaluations and information needed to determine usual functional performance. Social Services supports interviews and psychosocial data. Dietary contributes nutrition information. Providers must ensure diagnoses, orders, and clinical documentation support the resident’s needs. Leadership must provide oversight and remove barriers that prevent timely completion.
Facilities with strong QRP performance create systems, not last-minute fixes.
Best practices include:
• Daily review of upcoming ARDs and QRP-required assessments
• Routine IDT MDS meetings
• Use of high-risk MDS completion checklists
• Immediate communication of missing assessments or documentation
• Pre-submission MDS audits
• Ongoing education regarding observation periods and coding requirements
A proactive process is always more effective than trying to correct a dash after the assessment has been submitted.
Leaders should monitor:
• MDS completion timeliness
• Dash trends by section
• Late assessments and modified assessments
• QRP threshold reports and iQIES data
• Validation reports and recurring error trends as part of ongoing QAPI review
When a dash occurs, do not simply correct it. Investigate why it occurred.
• Was the resident assessed?
• Was documentation available?
• Was information communicated to the MDS team?
• Was additional education needed?
• Did a process failure occur?
Every dash represents a missed opportunity to accurately tell the resident’s story and demonstrate the quality of care provided.
The formula for success is simple: identify missing information early, communicate quickly, complete required assessments timely, audit before submission, and improve the process when gaps are found.
Protecting SNF QRP compliance and reimbursement does not begin at MDS submission; it happens every day through strong processes, interdisciplinary collaboration, and a commitment to accurately capturing the resident’s story.
Polaris Group supports SNF teams in strengthening MDS processes through proactive audits, real-time education, and interdisciplinary collaboration designed to improve accuracy, compliance, and outcomes.
