Although FY2027 does not bring any new MDS items or significant PDPM changes, CMS released an updated RAI User’s Manual effective October 1, 2026, that includes numerous clarifications and refinements to existing guidance. These updates do not change what is being assessed, but they may change how facilities interpret, document, and code certain items. Even small wording changes can influence assessment accuracy, reimbursement, quality measures, and survey readiness. The updates reinforce CMS expectations in several key areas, including resident interviews, skin and wound coding, isolation practices, respiratory therapy services, and documentation requirements. Understanding these refinements can help facilities ensure consistent coding practices, reduce compliance risk, and support accurate resident assessments.
Key Changes to Know:
- MDS Coding Authority (Chapter 3: Introduction): Federal MDS items must be
coded according to CMS instructions. State and payer requirements cannot modify
federal coding definitions or instructions for items outside Section S. - Race and Ethnicity (Chapter 3: A1005 Ethnicity and A1010 Race): Resident
responses may be collected upon admission and reused for subsequent assessments
within one year. Residents should be asked again annually. - BIMS and PHQ Interviews (Chapter 3: C0200-C0600 & D0150): When multiple
interviews are completed during the look-back period, the interview completed closest to
the ARD should be used for coding. - Shortness of Breath (Chapter 3: J1100) : Residents who report avoiding an activity
or position due to shortness of breath do not need to perform that activity to validate
their response. This is confirmation that the assessment of SOB lying flat does not
require observing the resident to be placed in the position to “prove” the deficit if the
resident reports breathing difficulty. - Falls (Chapter 3: J1800): CMS clarified assessment instructions for identifying and
coding falls following admission or reentry. - Skin Conditions (Section M): Additional guidance clarifies coding for pressure
injuries, surgical wounds, foot lesions, and wound care. A pressure injury that was
present on admission, healed, and later reopened is not coded as present on
admission. - Isolation Coding (Chapter 3: Section O – O0110M1): CMS clarified the criteria for
coding isolation related to an active infectious disease, including removing language
regarding how the infection was acquired. All other applicable isolation criteria must still
be met. - Respiratory Therapy (Section O: Therapy Services – O0390): Only qualifying
skilled respiratory therapy services should be captured on the MDS. Documentation
must support the skilled nature of the services rather than routine or maintenance-level
interventions. - PDPM (Chapter 6: PDPM Worksheet): The only additions made to this section were
wording swaps from “depression” to “signs and symptoms of depression” in reference to
the Mood Interview, and added text under Restorative Nursing on the PDPM Worksheet
added the reminder that coding “toileting programs do not require documentation of
days/minutes” (unlike the other Restorative Nursing Program items. These changes will
not impact practice.
Please reference the updated RAI Manual below for further clarification:
Minimum Data Set 3.0 Resident Assessment Instrument User’s Manual v1.20.11
Staying Current
Although FY2027 brings no major MDS or PDPM changes, the RAI Manual refinements provide important guidance for accurate assessment and documentation practices. We encourage facilities to review these updates with their interdisciplinary team and discuss any process adjustments needed to support compliance, documentation accuracy, and quality resident care.
As always, Synergy Care is committed to helping facilities navigate regulatory changes and implement best practices that support clinical excellence.