CMS’ Announcement of Section G Removal – A Brief Review

Friday, Dec 20th, CMS made an “unexpected announcement” surrounding the removal of Section G from the MDS from “all Federal item sets”. With the 10/1/19 inception of PDPM, Section GG (a completion requirement since Oct 2016 to capture amount of assistance provided for self-care and mobility tasks) has replaced Section G as a functional level reimbursement driver. Section G has remained a requirement on the MDS but is utilized for capturing short and long stay Quality Measures (QMs) related to function as well as determining the functional level reimbursement aspect of RUG based payor sources (such as Medicaid and some Managed Care entities). It is anticipated that this removal of Section G will take effect 10/1/2020. We will learn much more after further exploration of the MDS data sets and additional industry comments, however, to briefly review Section G vs GG and the potential impact to our SNF operations, please see below.

MDS Section G:


  • Most help needed for self-care and mobility (bed mobility, eating, toileting and transferring) in each MDS – 7 day look back period

Utilized to:

  • Drive reimbursement when payments are determined under the RUG based system (Medicaid and Managed Care not following PDPM)
  • Establish Functional Care Plan Goals
  • Report Functional QMs for short and long stay measures utilized in the 5 Star Rating system

Scoring Methodology:

  • Higher score = higher Dependence
  • Captured in the majority of cases directly from C.N.A’s via Kiosk documentation entries

Section GG:


  • Baseline or “usual performance” of self-care and mobility items during the first 3 days of the stay – prior to the benefit of intervention on the Initial Medicare Assessment
  • Self-care and mobility functional level during look back periods for IPA and DC assessments

Utilized to:

  • Replace section G in driving the functional level aspect of reimbursement for Medicare Part A stays
  • Establish Functional Care Plan Goals
  • Monitor Progress for QRP – Quality Reporting Program – Admission vs Discharge functional status

Scoring Methodology:

  • Higher score = higher Independence (inverse of Section G)
  • Captured in the majority of cases through nursing and therapy assessments with input from C.N.A’s, patients and other caregivers (requiring new systems of assessment and communication, vs Section G)

The proposed elimination of Section G from the MDS could potentially decrease confusion surrounding the process of accurately capturing Section GG information for Med A reimbursement process, QMs and QRP reporting. How states will manage RUG based Medicaid reimbursement and how other payor sources will adapt is yet to be seen.

Let’s Get to the Point:

Accuracy in Section GG just gained that much more importance!

Hoping this helps a bit. As always, if we can help with education and training surrounding the capture of accurate Section GG data, please feel free to reach out.

We will keep you posted as we learn more.

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