The FY 2027 RAI User’s Manual, effective October 1, 2026, includes several updates that impact MDS coding, resident interviews, skin conditions, respiratory therapy, isolation coding, and PDPM. While many changes provide clarification, several have direct implications for assessment accuracy and day-to-day coding practices.
7 Changes to Know
1. Pressure ulcers that reopen
A pressure ulcer that was present on admission, healed and later reopens should no longer be coded as Present on Admission.
2. Respiratory therapy requirements are more specific
Only skilled respiratory therapy services that are clinically indicated or medically necessary and require the skills of a respiratory therapist or respiratory nurse should be captured on the MDS. Routine maintenance, prophylactic treatments and resident self-administration do not qualify.
3. BIMS and PHQ interviews
When multiple BIMS or PHQ interviews are completed during the look-back period, the interview closest to the ARD should be coded.
4. Race and ethnicity responses can be reused
For subsequent assessments, a resident’s previous race and ethnicity response may be used if it was collected less than one year ago. After one year, the resident should be asked again.
5. Resident self-report for shortness of breath
When a resident reports avoiding an activity because of shortness of breath, the activity does not need to be performed to support the resident’s response.
6. Isolation coding has been clarified
The focus is now on whether the resident has an active infection with a highly transmissible or epidemiologically significant pathogen, rather than how the infection was acquired.
7. CMS reinforced federal RAI coding authority
CMS clarified that the RAI User’s Manual is the authoritative source for MDS coding instructions. State or payer requirements do not replace or modify federal coding instructions for items outside Section S.
For a complete breakdown of the changes, including additional coding clarifications and guidance, click here.Â
The Point Is: The FY 2027 RAI Manual updates may be small in some areas, but they can have a meaningful impact on how assessments are completed and coded. Staying current on these changes helps teams apply the latest guidance consistently and accurately.
If you have questions or need support navigating these updates, please contact us at reimbursement@qrmhealth.com. We’re happy to help.
