Section GG: What’s all the fuss about?
It all begins with the IMPACT Act of 2014…
The IMPACT Act requires the development of standardized patient assessment data that will enable:
- Quality care and improved outcomes
- Data Element uniformity
- Comparison of quality and data across PAC settings
- Improved discharge planning
- Exchangeability of data
- Coordinated care
And, this standardized data will be used to inform payment models.
The IMPACT Act mandates the collection and reporting of standardized data in the following PAC settings: SNF, HH, IRF, and LTCH.
One of the data category requirements in the IMPACT Act is Functional Status, and CMS has chosen Section GG as the standardized data set for all PAC settings. Section GG has been incorporated into the MDS, the IRF PAI, and LTCH CARE data set (LCDS) and, beginning 1/1/2019, the OASIS. The specific items and scoring are the same in every setting.
Payment models are shifting away from their own unique ways of measuring function (i.e., Section G for SNF, the FIM for IRF) and beginning to not only collect this uniform data but also to incorporate it into payment systems. In the SNF, PDPM uses Section GG as the basis of the functional score for PT/OT and nursing. The FY2019 IRF PPS Final Rule clarified that the FIM would no longer be used in the IRF setting and that data from Section GG would be used to calculate the case mix groups beginning in FY 2020. CMS will no doubt move away from functional info in Section M of the OASIS to Section GG once there has been sufficient Section GG data collected from providers.
The entire PAC industry is moving toward a Unified Post-Acute Care PPS – no doubt standardized information related to function as captured in Section GG will play a significant part in that system.