Have you ever looked at a policy update and thought, “How bad could it be?” That’s what many are thinking about the F641 accuracy of assessments change set to take effect on April 28, 2025. At first glance, it might seem like just another tweak in Appendix PP—but this one’s worth a second look.

The Centers for Medicare & Medicaid Services (CMS) has folded F642 (Coordination/Certification of Assessments) into F641. Sounds simple enough, right? But here’s where it gets serious. CMS is now instructing state survey agencies to refer communities to the Office of Inspector General (OIG) if they detect a pattern of inaccurate MDS coding. And by “pattern,” they mean just three MDS errors with the same miscoding. Yes, three.

What’s especially concerning is that CMS doesn’t factor in how many MDS assessments were completed during the review period or how large your community is. Whether you’re operating a 50-bed or a 250-bed community, three miscoded MDS entries could land you in hot water with the OIG and the Medicaid Fraud Control Unit. That doesn’t feel proportionate, does it? A smaller community reaching that threshold seems like a more significant issue than the same number of errors in a much larger one.

Most of the scrutiny is likely to land on MDS entries tied to new diagnoses—like schizophrenia—that lack clear documentation from a physician. That’s not just speculation; we’ve seen this play out during CMS’s ongoing schizophrenia MDS audits. So how do we keep the OIG from showing up at our door?

Educate, educate, educate. Anyone touching the MDS should be thoroughly trained and continuously reminded of the importance of accuracy. Only document what is verifiable and true. Keep the RAI User’s Manual open and accessible on a separate screen for quick reference. And don’t overlook the value of outside audits—whether random or routine, having a fresh set of eyes on your assessments can make all the difference.

Let’s not forget that this is about more than avoiding citations. Precise documentation directly affects the quality of care and the quality measures that reflect it. It’s about doing right by our residents, every day.

Stay well and stay informed!

For more on the regulatory language behind these updates, see Section 483.20(j) of the eCFR.

eCFR :: 42 CFR 483.20 — Resident assessment.