by
Amy Hasselkus
The Centers for Medicare and Medicaid Services (CMS) recently announced plans to revise the Minimum Data Set (MDS) for a 2004 release. In an attempt to make the MDS more clinically relevant, CMS invited members of ASHA, the American Physical Therapy Association, the American Occupational Therapy Association, and the American Association for Respiratory Care to a "listening session" last month. The organizations informed CMS about their concerns with the current MDS 2.0 and suggested changes.
ASHA presented concerns about the swallowing, cognitive, and communication/hearing patterns sections of the MDS. Specifically, ASHA reiterated concerns previously raised to CMS about the MDS’:
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lack of sensitivity to measurable performance changes
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lack of relevance to functional performance
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failure to identify the need for services in individuals with chronic illnesses.
In particular, changes to the swallowing and cognitive items were recommended.
To underscore the need for appropriate dysphagia services in skilled nursing facilities, ASHA provided incidence and prevalence data for dysphagia, stroke, malnutrition, and aspiration, as well as cost-savings benefits of dysphagia intervention by speech-language pathologists.
ASHA recommended inclusion of more sensitive seven-point scales, like the Functional Communication Measures (FCMs) developed as part of ASHA’s National Outcomes Measurement System (NOMS). For example, the swallowing FCM scale provides detailed information about the patient’s swallowing function, including diet levels and need for assistance and compensatory strategies. The current MDS item allows for the recorder to note only if a swallowing problem is present or not.
The NOMS attention and memory scales were proposed to replace the current MDS cognitive patterns section. These NOMS scales more accurately assess a patient’s functional abilities than the items on the MDS and would not add a significant number of items to the overall assessment form. FCMs for spoken language expression, spoken language comprehension, and motor speech also were presented for consideration.
ASHA also recommended expanding the training of MDS coordinators, who may or may not be specialists in the required areas of assessment. CMS confirmed that, in addition to determining reimbursement for a patient, the MDS also is used as a care-planning tool and needs to be sensitive to actual patient functional status and needs.
CMS is reviewing the recommendations and plans to confer again soon with ASHA and other organizations to continue the discussion on how to improve the MDS without increasing its length and complexity. ASHA welcomes comments from members on these recommendations or other changes to the MDS that would improve its effectiveness in identifying patients in need of services, care planning, and tracking outcomes and quality.
If you have comments, contact Janet Brown through the Action Center at 800-498-2071, ext. 4136, or by email at
jbrown@asha.org
; or contact Amy Hasselkus at ext. 4514 or by email at
ahasselkus@asha.org
.
Amy Hasselkus
is ASHA’s associate director of health care services in speech-language pathology.