Skilled Nursing Facilities Clarification for Classifying Medicare Evaluations

May 8, 2014

On a May 6, 2014, Skilled Nursing Facility (SNF) Open Door Forum, the Centers for Medicare & Medicaid Services (CMS) clarified existing policy regarding the coding of evaluations in the Minimum Data Set (MDS).

CMS stated:

  • The interpretation that any additional evaluation after the initial evaluation-regardless of the condition-is considered a re-evaluation is incorrect.
  • Coding of re-evaluations in the MDS is only appropriate if the re-evaluation is of a current condition that is being treated.
  • The CMS MDS is not based on Current Procedural Terminology (CPT) codes; therefore, evaluations and re-evaluations of the same condition should not be counted in the MDS, even if the record system used requires speech-language pathologists (SLPs) and therapists to code their sessions based on CPT codes.

CMS shared an example using cognition and swallowing. If the initial evaluation upon admission to the SNF was for cognition and a subsequent re-evaluation for cognition was performed, that re-evaluation is counted in the minutes for the MDS.

However, if the initial evaluation was for cognition and later in the course of treatment a swallowing evaluation is performed, the swallowing evaluation is not counted in the minutes for MDS, because it is a new condition that was not in the current treatment plan and is, therefore, a new evaluation rather than a re-evaluation.

CMS recommended that SNFs ensure that their processes for coding MDS minutes are consistent with the CMS clarification.

CMS also announced that updates to the Resident Assessment Instrument (RAI) Manual are expected to be released in September or October of this year.


Medicare guidance for Part A (inpatient) services is found in the Resident Assessment Instrument (RAI) Version 3.0 Manual. The manual provides specific direction about therapy services in Chapter 3, Section O. The MDS is a comprehensive summary of the patient's mental and physical issues, completed by the fifth day after admission to an SNF. Minutes in the MDS are recorded in 1-minute increments for the therapist's time spent in treatment, not initial evaluations or documentation.

CMS Resources

ASHA Resources

For more information, see ASHA's Medicare Guidance for SLPs in Skilled Nursing Facilities (SNFs). Questions may be directed to the health care economics and advocacy team at

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