Accurate MDS completion has become a regulatory lightning rod as the OIG and CMS intensify their scrutiny of long-term care documentation. This shift isn't merely procedural—it signals a comprehensive effort to identify potential fraud and ensure residents receive appropriate care based on accurate assessments.
The recent OIG work plan specifically targets resident falls resulting in major injuries, with investigators cross-referencing hospital claims against facility MDS documentation. When surveyors identify three or more examples of inaccurate MDS completion—now defined as a "pattern"—these findings may trigger referrals to OIG regional offices for fraud investigations. Beyond falls, diagnoses like schizophrenia are receiving particular attention, as inaccurate coding can significantly impact care approaches and medication regimens.
For facility leaders, this heightened scrutiny demands a systematic response. Start by ensuring your MDS coordinators have proper certification and education, then verify that all staff contributing documentation understand what they're recording. Implement regular audits to catch discrepancies before they become patterns, and foster interdisciplinary communication so different departments use consistent language and observations. Your compliance committee should conduct risk assessments, particularly for resident populations with high fall risks or complex diagnoses, and report findings transparently during QAPI meetings.
The stakes couldn't be higher—inaccurate MDS completion affects not just regulatory compliance but also reimbursement rates, Five-Star ratings, and most importantly, resident care quality. By strengthening your documentation systems now, you'll protect both your residents and your organization from the consequences of this unprecedented regulatory focus. Need guidance navigating these changes? Reach out to Verity Consulting for specialized assistance with your healthcare compliance challenges.
