Section GG is a standardized assessment utilized by the Centers for Medicare and Medicaid Services (CMS) in post-acute care settings. The assessment measures a patient’s need for assistance with self-care and mobility while also documenting the patient’s prior level of function.
Why was Section GG implemented?
The IMPACT Act of 2014 required CMS to develop a set of standardized outcome measures in post-acute care. Before Section GG‘s implementation, each setting tracked outcomes, but they were not standardized across settings.
CMS wanted a universal language that conveyed functional abilities to track patients as they move through the care continuum. This data helps CMS evaluate the services a patient receives and how it relates to functional improvements.
Before the measure’s implementation, CMS said that they were essentially comparing apples to oranges versus apples to apples. Thus, preventing comparison or consistency.
The Role Of Occupational Therapy In Scoring Section GG
Understanding the relationship between Section GG, reimbursement, and occupational therapy is critical in advocating for occupational therapy’s involvement early in the case.
If the OT practitioner is not the clinician completing the initial assessment, the practitioner should still share their findings with the reporting clinician.
Therapy is the most likely discipline to engage patients in the actual activity vs. gathering data primarily through interviews, so their observations and assessments are vital.
Occupational therapy practitioners are experts in self-care and functional mobility. Therefore, they are the perfect profession to assess Section GG in collaboration with other professionals.
CMS states the best way to assess the score on this assessment accurately is through observation. Although it is acceptable to gather information through a subjective interview, observation is the only guaranteed way to ensure accurate scoring.
OT’s influence on reimbursement and outcomes
Accurate scoring at evaluation and discharge is important for accurate outcome reporting and revenue.
- The patient is scored as more functional than their usual performance at the evaluation
- Patient has little space to make progress.
- Facilities will not receive adequate reimbursement for the services the patient needs.
- Negatively impact quality outcome reporting.
- The patient is scored as less functional than usual performance at discharge.
- Pay may appear to have declined in function.
- A patient may appear to have not improved at all.
- Negatively impact quality outcome reporting.
All of the above outcomes are not ideal and can have serious consequences for revenue and outcome reporting if happening on numerous patients.
Employing and utilizing an occupational therapist can help eliminate many of the above scenarios as they are experts in assessing self-care and functional mobility.
Relationship With Reimbursement
CMS acknowledges that patients with limitations are at an increased risk of function-related decline or complications due to impaired mobility. So this measure is intended to help facilities identify the amount and type of services a patient requires.
The assessment results should help trigger decision-making regarding steps that need to be taken to prevent adverse complications due to impaired mobility, such as referrals to occupational therapy.
Additionally, CMS recognizes that patients with a lower functional level typically have higher utilization. If a patient is scored as too functional on the initial assessment, Medicare will not provide sufficient reimbursement for all the services that the patient requires.
Currently, this measure is only utilized to directly influence reimbursement in skilled nursing facilities under the Patient-Driven Payment Model (PDPM). However, it is anticipated the measure may later be utilized in a more influential way for reimbursement in other settings.
Quality Ratings and Outcomes
Section GG is utilized in all settings to evaluate outcomes and quality metrics. Quality metrics, directly and indirectly, impact reimbursement in all post-acute settings.
Having a consistent way to assess the quality of care provides agencies with the necessary feedback to improve their overall care. Since these quality measures are publicly reported, it gives agencies feedback about how they stack up against others in the area.
CMS intends for Section GG to improve care coordination and discharge planning. The information agencies report helps CMS make alterations to payment models. CMS is slowly integrating quality outcomes into reimbursement bonuses or penalties.
Scoring Section GG
Section GG is assessed at admission and discharge at a minimum. Occasionally it is used during reassessments or recertification. Accurate scoring is vital for accurate reimbursement and quality outcomes. Utilizing the appropriate professional for each section helps ensure accurate scores.
When scoring Section GG, the clinician should not score the patient’s best or worst performance. We want to focus on their usual performance, meaning how the patient performs more than 50% of the time.
Gathering information from the care team will help develop an accurate picture of the patient’s function vs. using the observations of only one clinician.
Self-care and mobility items are on the assessment. Each item is scored on a 1-6 scale, with 6 being the most independent and 1 being the most dependent. So, the higher the overall score, the more functional and mobile the patient is. Scores are primarily based on the level of assistance required.
Observation vs. Instruction
To ensure accuracy, have the patient engage in the activity before providing any cues or physical help. It can be tempting to hand a patient their shoes or eyeglasses because they asked for your help, but this would not allow for an accurate score if the patient could do it themselves without intervention.
Although it seems simple, every step and item is part of the task. The patient would need to be able to do that at home if their goal is to be independent. During the assessment, only assist the individual if it is necessary for the task to be completed safely.
Self-care items are the same across settings except for LTCH, where bathe self includes only the upper body. LTACH does not report upper and lower body and footwear (F, G, and H).
Some important notes:
- Bathing: does not include washing hair.
- Upper Body Dressing: bra, dress, LTSO, abdominal binder, etc. Cannot be scored on the use of hospital gown
- Lower Body Dressing: includes donning lower limb prosthesis, knee braces, and shrinkers
- Toileting: Includes the ability to clean and use ostomy but does not include changing the ostomy bag. If they have an indwelling catheter, score on assist required for BM.
- Footwear: AFO, compression stockings
These are the mobility items below. Images are from the OASIS-D Manual, but descriptions are the same in all settings except LTCH.
Does Section GG have anything to do with the FIMTM?
Yes! Section GG replaced the Functional Independence Measure (FIMTM) in inpatient rehab facilities (IRF). The FIMTM was not utilized in all post-acute settings.
Additionally, the FIMTM had different scoring from similar assessments in other settings, and many practitioners complained about the lack of sensitivity or the grouping of certain activities together.
Removing the FIMTM when adding Section GG helps ensure CMS is not adding unnecessary regulatory burden by having practitioners score both assessments.
Why You Need an OT for Accurate Scoring of section GG
Occupational therapy practitioners are generalists by trade. They are experts in task analysis, problem-solving, and plan development. All OT practitioners (OTP) have training in self-care, activities of daily living, instrumental activities of daily living, functional cognition, vision, mobility, falls, mental health, and so much more.
If you’re looking for the perfect practitioner to meet all of your patient’s needs, an occupational therapy practitioner is the way to go.
So, if your employer or company is struggling to meet quality benchmarks or is consistently falling short regarding reimbursement, give OT a seat at the table.
If you’re an OTP in one of those settings, speak with your managers and use the information in this article to explain why OT is the solution to their issues. You can view a facility’s quality scores online for free and see how your employer shapes up to others in the area.
- CMS – Medicare Care Compare
- CMS- OASIS-D Manual
- Medbridge – Section GG Changes: What Do They Mean For Your Organization?
- CMS – Functional Measures
- CMS – Section GG Cross-Setting Training – Spring 2019
- AOTA – Proposed Changes to Quality Reporting for the 2019 Inpatient Rehabilitation Facility Prospective Payment System Rule
- AOTA – www.aota.org/value
- CMS- Outcome and Assessment Information Set OASIS-D Guidance Manual
- AOTA – www.aota.org/care