mds section gg: a guide for snf therapists · mds section gg: a guide for snf therapists

MDS Section GG: A Guide for SNF Therapists

RECORDED – LIVE WEBINAR PRESENTED BY:

MONTERO THERAPY SERVICES

COPYRIGHT 2016 WWW.MONTEROTHERAPYSERVICES.COM 1

CEU Information

This course has been approved for 1.5 Contact Hours or .15 CEU’s.

Your Certificate of Completion can be printed upon completion of the presentation and quiz. Your name and license number will be kept on file with Montero Therapy Services for State Licensing audit purposes. If you have not added your State License/Registration number to your Account Page, please do so as this is required for CEU credit.


Course Outline

Part 1: History Behind Upcoming Changes, Will Changes Impact All Residents?, How Will Changes Impact SNF and Therapy?

Part 2: Overview of New Section GG: New Terminology, New Rating Scale, When Is It Required/Not Required?

Part 3: Self-Care Section: New Questions, Definitions, Coding Scale, Setting Goals and Case Examples

Part 4: Mobility Section: New Questions, Definitions, Coding Scale, Setting Goals and Case Examples

Part 5: Recommendations for Implementing Changes Into Your Practice, Q&A


Today’s ObjectivesUnderstand the importance of Section GG and the Therapy’s Role in the MDS in relation to thetransition to Value Based Payment

Recognize when Section GG is required to allow for improved communication and collaborationwith MDS team

Learn accurate rules, coding, documentation and goal setting for Self Care and Mobility Items

Understand when payment penalties will apply due to missing documentation / data in GG

Incorporate Section GG requirements into therapy practice, documentation and rehabdepartment work flow


What’s Coming Our Way?New function-based set of MDS questions that will increase therapy involvement in the MDSprocess

These function-based questions are tied to functional outcomes, particularly for short termrehab residents. Targeting Medicare A residents receiving skilled therapy and/or nursing.

If lack of therapy involvement in the MDS process in the past, NOW is the time to get involved

New/Additional Section GG: Functional Abilities and Goals will be added


*DRAFT RAI Manual was replaced last week with FINAL Manual – This is time sensitive info with expected changes to come in next few weeksleading up to October 1st due to conflicting information in the Manual with MDS Assessment Instructions

Why Does This Change Involve Therapy?How is your current therapy involvement with facility MDS process?

Present Section G: Functional Status does not require therapy inputQuestions are populated based on daily documentation from direct caregivers based on resident performance

Nursing takes responsibility of this Section as it is based on resident status 24/7 over 7 day lookback

New Section GG: Functional Abilities and Goals will require input from PT and OTCoding for Self Care and Mobility Sections are based on an “Assessment”

Responsibility for this Section rests primarily with Therapy and Nursing

MDS coding will be based on an “Assessment” completed in a specific 3 day window.

Involves looking at Therapy and Nursing Data and making a clinical decision as to how to code function

Involves setting goals and predicting functional outcomes for end of Medicare stay/coverage Goal setting is not new for therapists, but new for the MDS and may be challenging for nursing initially as predicting functional outcomes is

not common



Let’s look at WHY this change is occurring

andHOW it will shape the future of SNF’s

…before we look at Section GG in detail

Why MDS Changes Now?Change stems from the IMPACT ACT of 2014

Improving Medicare Post-Acute Care Transformation Act of 2014Link to article explaining IMPACT ACT as it pertains to SNF Therapists

http://www.monterotherapyservices.com/clinical-information/impact-act-snf-therapists-need-know

ACT established a quality reporting program (QRP) for SNF’s (Different from QM’s = Stars)ACT requires standardization of data between SNF,HH, IRF, LTCH

Develop and implement quality measures and a way to report them

Step toward Value Based PaymentPayment based on Outcomes vs Volume

Step toward Quality Improvement in SNF – Focus on Medicare BeneficiariesUnify data, improve quality and outcomes through better sharing of info, coordinating care and dc’s



How GG Came About: QRP

IMPACT ACT required focus on areas of measure and a timeframe to collect the data.

Decision to focus on 3 areas to measure:

1. Falls (% of residents experiencing 1 or more falls with major injury)

2. Skin (% of residents with pressure ulcers that are new or worse)

3. Function (% of residents with an admission and discharge functional assessment (GG) and acare plan that addresses function)

Needed new questions to measure function – goal to standardize across all setting (IRF, Home care, SNF, Acute care, etc.)

Section GG as born!

GG will be tied to outcome tracking, progress, change in function, QRP and $$


Timelines and TimeframesData collection start date is 10/1/16 – for residents admitted on or after 10/1/16

Data will be collected from 10/1/16 through 12/31/16 for “Round 1”Will be used for FY 2018 payment (Oct 1 2017-Sept 30 2018)

Penalties will be applied to any SNF that has missing data during this time period MISSING DATA is identified by DASHES on the MDS for certain questions

MISSING DATA during the 3 month collection period will result in a large payment penalty lasting 1 year

80% of all submitted MDS’s need to contain 100% of all data items

Penalty: 2% reduction for SNF Part A revenue (market basket %) for the ENTIRE FY 2018

No penalty for poor outcomes yet


Timelines and TimeframesData collection using Section GG will occur at specified intervals:

1. On admission to the SNF

2. On discharge from the SNF

3. On “discharge” from PPS Part A services

Traditional Medicare Part A residents only (not Medicare Advantage)

Tracking outcomes of those primarily admitted for Part A coverage whether plan is to dischargeback to community or stay long term care


A Look at Section G: Functional StatusExisting Section G: Functional Status before looking at GG

Question G0110: ADL Assistance

See Handout

Filled in by nursing based on actual performance over 7 day lookback, coded based on Rule of 3

Note the Items

Note the Coding Scale

Important Section = 4 Items Determine ADL Score for RUG (RUA vs RUB vs RUC) = $$$


Intro to Section GG: Functional Goals and Abilities – Self CareNew Section on PPS 5 Day, OBRA DC and on new Part A PPS Discharge MDS

Questions GG0130: Self Care

See Handout

Will be filled in based on “Assessment” done in specific 3 day window (1st 3 days of Part A and last 3 days of Part A)

Note the Items


Note 2nd Column for Discharge Goal

Important= Performance Section = Missing data will result in penalty


Intro to Section GG: Functional Abilities and Goals - Mobility

New Section on PPS 5 Day, OBRA DC and on new Part A PPS Discharge MDS

Question GG0170 Mobility

See Handout

Will be filled in based on “Assessment” done in specific 3 day window (1st 3 days of Part A and last 3 days of Part A)

Note the Items


Note 2nd Column for Discharge Goal

Important= Performance Section = Missing data will result in penalty


Section G vs GG ComparisonSECTION G= ADL ASSISTANCE

Determines ADL score

Populates based on actual performance, not an assessment

7 day look back based on ARD

On every MDS, regardless of payer

5 point scoring scale, 0=Independent

Lack of therapy terminology

SECTION GG=FUNCTIONAL MOBILITY AND GOALS

Determines QRP status

Assessment of data needed to score based on resident “usual performance”

No look back, only 3 day window to assess, not based on ARD, based on specific days in PPS cycle

On select MDS’s, for Med A only

6 point scoring scale, 6=Independent

Uses therapy terminology (see next slide)


Section G vs GG Scoring ScalesSECTION G: 5 POINT SCALE

0 = Independent

1 = Supervision

2 = Limited Assist

3 = Extensive Assist

4 = Total Dependence

7 = Only occurred 1-2 times

8 = Activity did not occur

SECTION GG: 6 POINT SCALE6 = Independent

5 = Set-up / Clean-up help

4 = Supervision / Touching Assist

3 = Partial / Moderate Assist (Helper < half)

2 = Substantial / Max Assist (Helper > half)

1 = Dependent (Helper does 100%) OR 2 Assist is needed (ie: Walk 1 A with w/c follow would be coded Dependent)

9 = Not applicable

8 = Not attempted due to medical condition or safety concerns

7 = Resident refused


When Will GG Be Required?At the start of Medicare Part A coverage (Start=PPS Day 1)

◦ Will be captured on the 5-day PPS MDS

◦ Assessment of status and coded in the 1st 3 days of the Part A stay (won’t go by ARD)

At the end of the Medicare Part A stay/coverage if resident is staying in facility◦ This a new MDS Assessment specific to this circumstance “Part A PPS Discharge MDS”

◦ Assessment of status and coded in the last 3 days of Part A stay (won’t go by ARD)

When resident is discharged from the facility after a Medicare Part A stay◦ The OBRA DC MDS will be combined with the Part A PPS Discharge MDS

◦ Section GG will be required when the DC is planned vs unplanned

◦ *** Inconsistencies in DRAFT vs FINAL Manual and PPS MDS Instructions-expect change prior to Oct 1st


RAI Manual Definition of “Discharged”Already confusion around the word “discharged” between therapy and nursing. Therapy DCrefers to the last day of therapy program, or the day the DC Summary is completed. Nursingrefers to DC as the day the resident left facility

Now RAI Manual redefining “discharge” by correlating “discharge” to the Last Covered Part ADay (New MDS called “PPS Part A Discharge”) done when resident is “staying”

◦ Discharged……from Medicare Part A = Last covered day

◦ Discharged….from Facility = Typically the day after the last covered day

◦ Discharged….from Therapy= Typically the last day of Part A coverage, but does not need to be

Need to ensure when using term “discharge” that both therapy and nursing are talking aboutthe same thing


Exceptions – Section GG Not Needed When…

1. Unplanned Discharge from SNF (can’t truly judge functional improvements)

2. DC to acute hospital

3. Stay at SNF is less than 3 days total (Med A coverage is less than 3 days total)

*Does not mean the PPS Part A Discharge Assessment is not needed, only that Section GGshould not be required within that Assessment …..still need to complete falls, skin, etc

*This is the issue in the Final RAI Manual release that may change = GG may be required forunplanned discharges in the future


GG Will be Needed For: Start of Medicare Part A Stay


When “5-day assessment” is selected as the type of MDS in Section A, Section GG will open up

Can be a stand alone 5-day PPS MDS or an Admission/5-day PPS combined assessment

Dates entered into A2400 will set the Admission 3-day assessment windows

Window is always PPS Day 1,2,3 to review data and complete assessment

May have ARD as Day 8 but GG needs to be completed by Day 3

GG Will Be Needed For: Part A PPS Discharge (Resident stays in SNF)


Done when resident is discharged from Medicare A and stays in facility (cut or BE)

New MDS created for this purpose

Can be combined with other MDS’s

GG will open if “yes” is answered A0310

Dates entered into A2400 will set the Discharge 3-day assessment window

Window is always last 3 days of Part A stay for review of data and completion of assessment

ARD of MDS will match the Medicare End Date for the DC MDS

GG Will Be Needed For: Discharge from SNF After Part A Stay


Existing OBRA DC MDS done when resident is discharged from SNF

Can be combined with other MDS’s. Required in some instances.

GG will open if discharge is Planned and if SNF Part A Discharge is Yes **Currently some discrepancy in Final Manual released vs Instructions of Forms ** May change to included Planned and Unplanned**

Dates entered into A2400 will set the Discharge 3-day assessment window

Window is always last 3 days of Part A stay for review of data and completion of assessment

Medicare End Date may not match LCD in this scenario – depends on reason for DC

Medicare Stay End Date Accuracy


A2400 Medicare Stay End Date NEEDS to be accurate for proper scoring

RAI Manual - See attached algorithm

Biggest culprit of Short Stay issues

Was the Discharge Planned or Unplanned?

IMPORTANT QUESTION WITH POTENTIAL PAYMENT IMPLICATIONS

Therapy should have input into this answer

RAI Manual defines Unplanned DC

Unplanned is MORE than discharges to the hospital or leaving AMA. It also includes a discharge from facility where the resident decided to leave prior to the date recommended by therapy/team.

When coded “unplanned” the GG data will be excluded from the QRP outcomes

Not fair to include DC performance outcomes if resident is leaving before therapy is complete


** Keep an eye out for more discussion on this – Final RAI

Manual release has discrepancy for GG completion ** Clarification

likely in next few weeks

GG0130: SELF CARE1. Review of MDS questions / item set definitions

2. Coding Scale

3. Admission Performance and Discharge Goal

4. Discharge Performance

5. Case Examples


GG0130: SELF CAREEating

◦ Function of food to mouth

◦ Does not include tube feeding like Section G

Oral Hygiene◦ Specific to oral hygiene, including

management of dentures

◦ Section G “Personal Hygiene”

Toileting Hygiene◦ Similar to Section G “Toilet Use”

◦ Excludes transfers to toilet (G)


Coding Scale vs Therapy Documentation

Important for therapist to know MDS definitions of assist level (and tasks) even if they will have no contact with MDS. Therapy will be discussing resident status with MDS nurse and

understanding of terminology is critical.


Intermittent Supervision, Supervision, Stand By Guard, Contact Guard, Cues Only

Min Assist, Mod Assist of 1

Max Assist of 1

Total Assist, Dependent, or Assist x 2 at any level

“Usual Performance”Coding for GG is based on “Usual Performance”

New MDS Term

“Not best”

“Not worst”

Lacks objectivity!

Need to have documentation to back up how GG is coded


Admission Performance & DC Goal

Admission Performance and Discharge Goal:

◦ Assessment completed on PPS Day 1, 2 or 3

◦ Usual Performance

◦ DC Goal refers to projected status / goalupon completion of Medicare Astay/coverage

◦ Keep in mind resident may not have 100days and may need days beyond MedicareDays to reach full potential

◦ Ensure DC Goal correlates with Therapy Goal


Some Good News….


The requirement for DC Goal setting is at least 1 Self Care OR Mobility goal must be coded on 5 day MDS. Do not need to set goals for each item, even if

goals exist in therapy documentation or care plan.

More Good News….


Only place in GG it is OK to have DASHES - No Penalty in DC GOAL SECTION…NEVER DASHES in PERFORMANCE SECTION

Admission Case Example #1 - EATING


0 3 0 4

On the Admission Assessment, 03 (Mod Assist) was coded based on review of Day 1 and Day 2 documentation. OT Eval was completed on Day 2 and found that resident had potential to feed self full meal independently with occasional steadying, with addition of AFE and OT program. DC Goal of 04 was selected and matched Long Term Goal on OT Initial Evaluation.

Discharge Case Example #1 - EATING


On the Admission Assessment, 03 (Mod Assist) was coded. OT Eval was completed on Day 2 and found that resident had potential to feed self full meal independently with intermittent steadying with addition of AFE and OT program. DC Goal of 04 was selected and matched Long Term Goal on OT Initial Evaluation. Upon completion of Occupational Therapy and 30 days of Medicare Part A, the resident is being cut from Part A due to no further skilled needs. Upon DC the resident was able to feed herself independently with intermittent adjustment and steadying of AFE by staff.

0 4

Admission Case Example #2 - EATING


8 8 - -

On the Admission Assessment, 88 was coded. Codes 07, 09 and 88 are not allowed in the DC Goal box. Dashes are allowed in this section without penalty. If SLP was going to work on a return to PO and had goals set for eating, a DC Goal could be coded here.

GG0170: MOBILITY1. Review of MDS questions / item set definitions

2. Coding Scale

3. Admission Performance and Discharge Goal

4. Discharge Performance

5. Case Examples


GG0170: MOBILITYSit to lying and Lying to sitting:

◦ Includes full movement in supine – sit and unsupported sitting

Chair/bed-to-chair transfer:◦ Includes standing lift and mechanical

lifts

Toilet Transfer:◦ Includes bedside commode

Walk/Wheel 50 feet with 2 turns:◦ Turns are 90 degrees any direction◦ If resident walks and wheels, both

should be coded


Coding Scale vs Therapy Documentation

SAME CODING SCALE FOR SELF CARE AND MOBILITY


Intermittent Supervision, Supervision, Stand By Guard, Contact Guard, Cues Only

Min Assist, Mod Assist of 1

Max Assist of 1

Total Assist, Dependent, or Assist x 2 at any level

Admission Performance & DC Goal

Admission Performance and Discharge Goal:

◦ Assessment completed on PPS Day 1, 2 or 3

◦ Usual Performance

◦ DC Goal refers to projected status / goal upon completion of Medicare A stay/coverage

◦ Keep in mind resident may not have 100 days and may need days beyond Medicare Days to reach full potential

◦ Ensure DC Goal correlates with Therapy Goal


REMEMBER….


The requirement for DC Goal setting is at least 1 Self Care OR Mobility goal must be coded on 5 day MDS. Do not need to set goals for each item, even if

goals exist in therapy documentation or care plan.

REMEMBER….


Only place in GG it is OK to have DASHES - No Penalty in DC GOAL SECTION…NEVER DASHES in PERFORMANCE SECTION

Admission Case Example #1 - Chair Transfer


On the Admission Assessment, 04 was coded based on review of Day 1 and Day 2 documentation. PT Eval was completed on Day 2 and found that resident had potential to progress to prior level of function - independent. DC Goal of 06 was selected and matched Long Term Goal on PT Initial Evaluation.

0 4 0 6

Discharge Case Example #4 - Chair Transfer


On the Admission Assessment, 04 was coded based on review of Day 1 and Day 2 documentation. PT Eval was completed on Day 2 and found that resident had potential to prior level of function -independent. DC Goal of 06 was selected and matched Long Term Goal on PT Initial Evaluation.

Upon DC Assessment review on the Last Med A Day (Last Day of Therapy), a review of therapy and nursing documentation reveals the resident is independent with Bed-Chair transfers.

0 6

Admission Case Example #2 - Toilet Transfer


On the Admission Assessment, 88 based on review of Day 1 and Day 2 documentation. OT Eval was completed on Day 2 and found that resident had potential to progress to Min Assist after acute medical issue resolved. DC Goal of 03 was selected and matched Long Term Goal on OT Initial Evaluation.

8 8 0 3

Admission Case Example #3 - Walk 50’ with 2 Turns


On the Admission Assessment, 01 was coded based on review of Day 1 and Day 2 documentation. PT Eval was completed on Day 2 and found that resident had potential to progress to prior level of function - independent. This was reflected in PT documentation. Team chose not to set DC Goal in this area as DC Goals were set in 2 other areas.

- -0 1

Documentation to Support GG

Performance codes need to be backed up by documentation

CMS / RAI Manual will not dictate how, will be up to each facility

Surveyor needs to be able to come up with same coding

GG is tied to QRP and could be subject to manipulation

Ensure your SNF has a MDS Policy and Procedure in place that outlines how the SNF is handling documentation and coding of Admission and Discharge Assessments

Include specifics on Section GG

MDS focused surveys


Documentation to Support GGSection GG Admission and Discharge Performance sections are “Assessments” for the MDS vs a look-back calculation

Intent is to look at more than 1 data source to decide (Therapy, Nursing, etc)◦ Not intended to use C.N.A. documentation as main source – like Section G

Need to record date of Assessment◦ If Admission Assessment can be done PPS Day 1, Day 2 or Day 3 and you choose Day 2, the resident’s

performance on Day 3 is not factored into coding decision◦ Can sign MDS Section GG date it is done (similar to BIMS)◦ Can document Assessment and scoring elsewhere and enter into MDS when coding other sections after ARD

(as long as you can reproduce document)

DC Goal can be done by 1 discipline, can be in Care Plan or Therapy Notes◦ Ensure DC Goal on MDS matches Care Plan goal and/or Therapy goal◦ Do not need to rewrite goals somewhere else

**See Sample Data Collection Tool in Handouts


Sample Data Collection Tool


*See handout for full sizesample

WHO Should Code GG? Therapy? Nursing?RAI Manual will not dictate who, only that Federal and State regulations are followed

Keep in mind….this is considered an “Assessment”

Should be a team approach to decide based on the sharing of information from each discipline and review of written record

◦ Can keep it simple and have a team discussion for those in 3 –day assessment windows at morninghuddle – designate 1 person to write an “Assessment Note” with decision for coding and why

◦ Tough for Friday and Saturday admissions

How each SNF handles this should be based on individual circumstances◦ Goal is to have 1 person oversee GG to be the “gatekeeper” for consistency, inappropriate dashes, etc

◦ Typically should be the MDS Nurse to sign off on Section GG, though Therapist would not be out of thequestion


The Flow of GGSample Scenario

New Medicare Part A Admission arrives on 10/3/16◦ Day 1: PT Evaluation◦ Day 2: OT Evaluation◦ Day 3: Last day Admission Performance Assessment & Discharge Goals can be completed on the MDS

◦ Therapy and nursing review current documentation and determine “usual performance” for GG

◦ DC Goal is set in 1 area of Mobility based on PT Evaluation Goals

Resident receives skilled therapy and nursing services

Therapy, Social Worker and resident discuss status and projected DC date based on progress. Date is selected for the following week for return home.

Team sets reminder of 3 day Assessment window for Discharge

Team reviews documentation and determines “usual performance.” Assessment completed on Last Covered Medicare A Day and recorded on MDS


Food for Thought….CMS will begin acquiring data on Function at the Start and End of Medicare Part A stays

◦ Track status at the start and compare to end◦ Was progress achieved? Was it the progress that was predicted?◦ Models Functional Limitation Reporting (G-Codes) for Part B

What if….◦ What if 100 days of Medicare Part A are used, a Rehab RUG was maintained the whole time, and there is no

difference in Self Care / Mobility from the Admission Assessment to Discharge?◦ What if there was minimal progress noted in Performance, and the RUG was RUB the whole time?

CMS can see if progress, or lack of, in multiple functional areas was made just by looking at MDS coding

◦ Will this be cause for denial? Or trigger more/less ADR’s?

We now have multiple MDS sections that have data collected for Self Care, Mobility◦ Go110 ADL’s, G0300 Balance during transfers and walking, GG◦ Will they match???? Should they???


Key Points to Remember….Section GG on pertains to Medicare Part A residents (for now)

For admissions, decision on coding for GG, “Assessment,” must be done by PPS day 3

For residents discharged from Part A, whether they are staying LTC or leaving, GG “Assessment” must be done withinthe last 3 covered days of the stay.

For now, unplanned discharges are excluded from GG, though this may change prior to Oct 1st

NEVER DASHES in Admission or DC Performance Sections

OK DASHES in DC Goal Section

Make sure you have AT LEAST 1 DC GOAL in any area of function – only need 1 for now

Important for therapy to understand requirements of Section GG and be involved in MDS coding as FUNCTIONALOUTCOMES are tied to Rehab Progress

Want GG to reflect therapy documentation to show true outcomes…what if MDS does not show progress but therapydocumentation does??

Payment methodology structure headed for change…therapists should be ahead of the curve!


References: Use Your PDF for Live Links

Sources in addition to the hyperlinks provided throughout the material include:

www.cms.gov

AANAC.ORG

RAI Manual – Final – Released 8/25/16 https://downloads.cms.gov/files/MDS-30-RAI-Manual-V114-October-2016.pdf

IMPACT ACT Article: http://www.monterotherapyservices.com/clinical-information/impact-act-snf-therapists-need-know

MDS SECTION GG Article: http://www.monterotherapyservices.com/clinical-information/mds-changes-impacting-snf-therapists-section-gg

RAI State Coordinator List (updated 8/25/16) – can email to ask specific questions as needed

Section GG: Four-Part CMS YouTube Training Video Series (8/16)

1. https://www.youtube.com/watch?v=pNgQ3OSaxYg

2. https://www.youtube.com/watch?v=M1JdQxjNOqE

3. https://www.youtube.com/watch?v=ok3U2-mQymk

4. https://www.youtube.com/watch?v=oRmMT_uYS8Y


http://www.cms.gov/

http://www.aanac.org/

https://downloads.cms.gov/files/MDS-30-RAI-Manual-V114-October-2016.pdf


http://www.monterotherapyservices.com/clinical-information/mds-changes-impacting-snf-therapists-section-gg

http://www.monterotherapyservices.com/wp-content/uploads/2016/08/State-RAI-Appendix-B-08-25-2016.pdf

https://www.youtube.com/watch?v=pNgQ3OSaxYg

https://www.youtube.com/watch?v=M1JdQxjNOqE

https://www.youtube.com/watch?v=ok3U2-mQymk

https://www.youtube.com/watch?v=oRmMT_uYS8Y


Can’t think of a question now? Email us later at [email protected]. All our courses include Q&A on the material as needed.

Individual Members.. You can ask a question any time…Visit our

JustAsk! Q&A Forum

mailto:[email protected]

http://www.monterotherapyservices.com/just-ask

Continuing Education

Program Evaluation

Click here to complete online now: www.MonteroTherapyServices.com/course-evaluation

Title: MDS Section GG: Guide for SNF Therapists

Location: Live Webinar

Date Course Completed: September 1, 2016 12:00-1:15 EST

Presenter(s): Dolores Montero, PT,DPT,GCS, RAC-CT

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DisclaimerThis information for this presentation was current at the time it was published. Source documents and links are provided. Due to the frequent change in Medicare policy, participants should verify policy change prior to implementing information into practice.

This presentation was prepared to provide general information on the subject material. Participants are encouraged to further review the specific statutes, regulations and other materials for a full understanding of how to utilize this information in practice.

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mds section gg: a guide for snf therapists · mds section gg: a guide for snf therapists

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