MDS Updates: What Post-Acute Care Providers Need to Know
The Centers for Medicare & Medicaid Services (CMS) has released the final Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) User’s Manual on October 1, 2025, bringing important refinements that directly affect care planning, documentation, and reimbursement.
At Health Advisory Partners by Aegis Therapies® (HAP), we know that even seemingly small MDS changes ripple across the entire post-acute care workflow. This blog provides an in-depth overview of the updates, their practical implications, and strategies for preparing your team for successful implementation.
Why the MDS Matters
The Minimum Data Set (MDS) 3.0 is the standardized assessment tool used across all Medicare- and Medicaid-certified nursing facilities. It is the foundation of the federally mandated Resident Assessment Instrument (RAI) process, which serves three essential purposes:
Care Planning – Ensuring resident needs, strengths, and goals are reflected in an individualized care plan.
Quality Measures – Feeding data into national quality metrics that reflect your facility’s performance.
Reimbursement – Determining case-mix classifications and payment rates under the Patient-Driven Payment Model (PDPM).
In short, accurate MDS assessments drive both clinical outcomes and financial sustainability. Missteps in coding or interpretation can affect resident care, compliance reviews, and revenue integrity.
Changes to the MDS Manual
The final MDS 3.0 RAI User’s Manual includes several refinements that nursing homes must adopt as of October 1, 2025. Let’s summarize the most significant changes section by section as outlined on the CMS website:
Section A: Identification Information
· A0800 (Gender) replaced with A0810 (Sex).
· A1250 (Transportation) replaced with A1255 (Transportation).
These updates reflect evolving data standards for greater accuracy.
Section GG: Functional Abilities
· GG0130 (Self-Care) and GG0170 (Mobility) restructured for clarity and aligned with other manuals.
Since Section GG affects PDPM reimbursement and outcomes, staff training is essential.
Section J: Health Conditions
· Clarified definitions of falls and major injuries—critical for compliance and quality reporting.
Section K: Swallowing/Nutritional Status
· Refined guidance for coding K0300 (Weight Loss) and K0310 (Weight Gain) to improve nutrition tracking and care planning.
Section O: Special Treatments, Procedures, and Programs
· Added O0390 (Therapy Services).
· Revised O0400 (Therapies).
· Removed O0420 (Distinct Calendar Days of Therapy).
These updates streamline therapy data collection and impact reimbursement.
Additional Clarifications
Minor corrections and alignments appear throughout; providers should review the detailed change tables in the manual.
Why These MDS Changes Matter
While the updates may appear technical, their impact is significant. Every adjustment affects how your staff records, interprets, and acts upon resident data. Here’s why it matters:
Care Planning Accuracy – Updated definitions and clarifications reduce ambiguity, ensuring individualized care plans are built on precise data.
Survey Readiness – CMS surveyors will expect facilities to implement these changes immediately. Inaccurate or outdated coding could result in deficiencies.
Reimbursement Integrity – Sections like GG and O feed directly into PDPM calculations. Missteps here can lead to underpayment, overpayment, or compliance risk.
Interdisciplinary Collaboration – With therapy, dietary, nursing, and social services all contributing to the MDS, clear guidance fosters stronger communication across disciplines.
Ultimately, the MDS serves as a holistic portrait of each resident. Changes to the manual refine that portrait and ensure that facilities are aligning care delivery with regulatory expectations and resident-centered goals.
Using RAI for Resident-Centered Care
Beyond compliance, the RAI process is designed to help facilities deliver the highest possible quality of care and quality of life. When used effectively, the MDS enables:
Holistic Resident Assessments – Looking at residents as individuals, not just clinical cases.
Goal-Oriented Care Plans – Tracking whether residents are meeting care goals and adjusting plans as needed.
Interdisciplinary Engagement – Incorporating input from nursing, therapy, dietary, social work, pharmacy, and recreation teams.
Continuous Improvement – Identifying trends in resident status, outcomes, and facility practices to drive quality improvement initiatives.
As CMS refines the MDS, the expectation is clear: facilities must use the data not only for compliance but also for meaningful care improvements.
Implementing the October 2025 MDS Changes
Implementing MDS updates requires more than downloading the latest manual. Post-acute care providers should take a proactive approach to ensure a smooth transition. Here are five steps to consider:
1. Educate Your Team
Start by educating your team: distribute the updated manual to MDS coordinators and other staff, and highlight key changes during meetings or training sessions.
2. Review Policies and Procedures
Next, review and update your policies and procedures so documentation protocols and care planning workflows reflect the revised guidance.
3. Train Interdisciplinary Staff
Interdisciplinary training is also critical; therapy, dietary, and social services teams should all understand how the updates affect their areas, and scenario-based exercises can help reinforce accurate coding.
4. Audit Current Practices
Conduct internal audits of recent MDS assessments to identify where changes will have the biggest impact and address any gaps before October 1 to avoid compliance issues.
5. Leverage Technology and Partners
Finally, make sure your EHR and assessment systems are updated for the new fields, and consider partnering with organizations like HAP for education, compliance monitoring, and clinical support.
How HAP Can Help
At HAP, we specialize in helping post-acute care providers navigate regulatory change with confidence. From staff education to clinical program development and compliance audits, our services are designed to strengthen your facility’s ability to deliver high-quality, patient-centered care while maintaining financial integrity.
With the October 2025 MDS changes, HAP can support your organization by:
Conducting mock audits to ensure readiness.
Offering consultative guidance for care planning, therapy alignment, and interdisciplinary communication.
Supporting quality improvement initiatives tied to the new MDS measures.
The release of the MDS 3.0 RAI User’s Manual is an opportunity to refine your facility’s approach to care, strengthen interdisciplinary collaboration, and ensure accurate reimbursement under PDPM. By preparing your staff now, updating your documentation processes, and embracing the holistic vision of the RAI process, your facility can move into the October 2025 changes with confidence.
At HAP, we’re here to help you succeed not just in compliance, but in achieving the highest possible outcomes for your residents. Connect with HAP today to for help in implementing these MDS updates.
Health Advisory Partners welcomes all persons in need of its services and does not discriminate on the basis of age, disability, race, color, national origin, ancestry, religion, gender identity, sexual orientation or source of payment. Interpreter Services are available at no cost. Please visit Health Advisory Partners for assistance. Servicios de interpretación están disponibles sin costo. Visite su sucursal local de Aegis Therapies para recibir asistencia. 我们提供免费传译服务。请探访您的本地Aegis Therapies地点以获得协助