TOPIC: LEVEL II EVALUATION &
DETERMINATION

Originally, Resident Reviews—Level II post-admission evaluations—had to be conducted annually; hence, the original name of the program was Preadmission Screening and Annual Resident Review, or PASARR, which is the title that is still in the rule.

No, a nursing facility cannot perform a Level II pre-admission evaluation or resident review. 42 CFR §483.106(e)(iii) prohibits nursing facilities (or any entity that has a direct or indirect affiliation or relationship with a nursing facility) from performing Level II evaluations. Because nursing facilities are responsible for providing nursing services, it is considered a conflict of interest for them to determine the individual’s service needs. Additionally, while nursing facilities are not prohibited from performing Level I screens, both Level I screens and Level II evaluations must be completed prior to admission.

Level II evaluations for individuals with intellectual disabilities and/or related conditions: According to 42 CFR 483.106(e)(1) and 42 CFR §483.106(e)(2) of the Code of Federal Regulations (CFR), evaluations for individuals with intellectual disabilities (ID) and/or related conditions (RC) are the responsibility of the state intellectual disability authority (SIDA). Thus, the state intellectual disability authority may complete ID/RC Level II evaluations. 42 CFR 483.106 (e)(1) allows the SIDA to delegate, by subcontract, the evaluation to another entity, but the SIDA must retain ultimate responsibility for the performance of this duty. Additionally, 42 CFR 483.106(e)(1)(iii) explicitly prohibits the SIDA from delegating evaluations to a NF or an entity that has a direct or indirect affiliation or relationship with a NF. NFs and their staff may not perform Level II evaluations on behalf of the SIDA.

Since the ICD-10-CM coding went into effect on October 1, 2015, some State PASRR programs have reported an increase in PASRR volume, particularly in referrals for Level II Resident Reviews. The increase is largely attributed to the computer algorithm that converted ICD-9 codes to ICD-10 codes. NF residents coded under ICD-9 as having a minor depression - i.e. not a depression severe enough to meet PASRR’s definition of “severe mental illness” (SMI) - were, when the system converted to the ICD-10 system, being coded as having a major depression (specifically many residents received a coding of F32.9 ”major depression – unspecified”).

This presentation will describe multiple ways nursing facility residents can be assessed through PASRR and aims to identify practices that can improve compliance with nursing facility requirements. Practices that can increase usefulness of Level II resident review and status change activity will also be discussed.

This webinar aims to clarify the relationship between PASRR Level II evaluations and dementia and mental illness. Current concerns about practices related to dementia and mental illness will be reviewed and the responsibilities of Level I screeners and Level II evaluators will be addressed. Areas of confusion related to dementia and mental illness will be identified and training resources will be recommended.