PDPM Case Mix Project Update

NYSHFA participated in a call today with the DOH and Myers & Stauffer (M&S) regarding the State’s transition to PDPM. The following is a summary of the discussion.

Additional MDS Data Needed

M&S has completed an analysis of MDS data from Q1 2022 through Q3 2023, as well as daily MDS submission files from Q4 2022 through Q1 2024.

In its analysis, M&S found that only two of the five PDPM components can be accurately utilized from this data: the Nursing component and the Non-Therapy Ancillary (NTA) component. The remaining three components, Physical Therapy, Occupational Therapy and Speech Therapy cannot be used in the data algorithms due to a lack of sufficient provider data.

Consequently, further additional data fields will be requested by the DOH to complete a thorough analysis of all five PDPM components. Specifically, DOH will be issuing an upcoming DAL requiring skilled nursing facilities to complete the following MDS items, in addition to those already required, beginning as soon as 6/1/25.

1. I0020 – Indicate the residents primary medical condition category
2. J2100 – Recent Surgery Requiring Active SNF Care
3. O0400D – Respiratory Therapy

These three fields are not required by CMS as part of the OBRA assessment; however, they are key elements in PDPM that will assist the DOH and M&S in analyzing the assessment data for future case mix adjustments.

Two-Step PDPM Transition Process – Interim Case Mix Methodology

This data collection process will turn the PDPM case mix transition into a two-step process but will allow for a case mix adjustment to occur sooner. This interim case mix methodology will rely on the Nursing and NTA components only. It is anticipated that this interim methodology would be implemented in the Fall of 2025.

Following this data collection and analysis, M&S stated that they will be better equipped to work more closely with the Department and our industry on specific ideas, impacts and elements of the assessments.

During our discussion, DOH raised the following questions:

• Is the 6/1/25 start date to collect the additional MDS data feasible?
• Is it possible to update the assessment retroactively? (The consensus on the call was that a prospective analysis is the more reasonable approach.)
• Are there technology or training constraints? 

Next Steps – Final Methodology

M&S outlined the timeline for collecting additional data and conducting further analysis:

• Assume 6/1/25 as the earliest starting date for additional data collections.
• Several months of data are needed. M&S requires at least 3 months but would prefer 6 months.
• Implement an interim case mix methodology in the Fall of 2025 that may rely only on the Nursing and NTA components while data is collected.
• The resulting target for beginning analysis of this new data is 11/1/25.
• The resulting target to present a PDPM model to stakeholders for feedback and possible recommendations is Spring 2026.
• Final PDPM methodology implementation target is Fall 2026.

NYSHFA will continue to work together with the DOH and M&S and provide Member updates as the State’s transition to PDPM moves forward.

NYSHFA | NYSCAL CONTACTS:

Stephen B. Hanse, Esq.
President & CEO
518-462-4800 x11

Carl J. Pucci
Financial Consultant
518-462-4800 x36