Executive Summary

The Centers for Medicare & Medicaid Services (CMS) has released the final version of the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) User’s Manual v1.20.1. This version, posted on August 29, 2025, supersedes earlier drafts and introduces several critical updates that Skilled Nursing Facilities (SNFs) must implement by October 1, 2025. This white paper outlines the most impactful changes and guides administrative teams to ensure compliance and optimize care documentation.

Updates can currently be seen in red italics within the manual. Click HERE for the latest version.

Key Updates by Section

Section A: Administrative Items

• A8000 (Gender) has been removed and replaced with A0810 (Sex) to align with updated CMS terminology.
• A1250 (Transportation) is replaced by A1255 (Transportation).

Section GG: Functional Abilities and Goals

Section GG remains one of the most confusing sections of the MDS.  CMS updated guidance in several patient examples and also regarding a resident’s abilities, as noted below.

• Enhanced clarity in coding Self-Care and Mobility items.
• Guidance is provided regarding the resident’s ability to complete the activity regardless of whether the activity is being/will be routinely performed.
• Facilities should review updated definitions to ensure accurate assessment and documentation.

Section I: Active Diagnoses

With the initiation of PDPM, correct ICD10 codes can impact reimbursement.  These codes are updated annually with a crosswalk released by CMS.

• CMS has submitted an updated ICD-10 database for I0020B, although it is not yet available on the CMS PDPM webpage, you can download the zip file HERE.

Section J: Health Conditions

The definition of Falls with Major Injury has been revised.  Accurate recording is vital to its potential impact on Quality Measures.

• Revised definition of Falls with Major Injury:
  • Clarification in that Pathologic fractures (e.g., due to bone disease) are not considered major injuries from falls.
  • Physician documentation is essential to differentiate between traumatic and pathologic fractures.

Section K: Nutritional Status

• Updated guidance for coding two sections regarding weights close to the time frame defined:
  • K0300: Weight Loss
  • K0310: Weight Gain
• Facilities should ensure dietitian and nursing documentation aligns with the new criteria.

Section O: Special Treatments, Procedures, and Programs

There is streamlined guidance on the recording of therapy time and clarification around the modalities that include:  Individual, Concurrent, and Group.

• Most therapy items under O0400 have been removed.
• New item O0390 introduced to streamline therapy documentation.
• Expanded guidance on modality definitions improves clarity and consistency.

Section R: Social Determinants of Health

• Removed for the final manual. Facilities should disregard any prior guidance related to Section R.  Transportation remained in Section A.

Section X: Correction of Records

• Updates provided for modifying and inactivating records in iQIES.
• SNFs should review internal workflows to ensure proper record management.

Recommendations:

1. Download the Correct Manual: Ensure your team is using the version posted on August 29, 2025.
2. Educate Your Team: Conduct in-service training for MDS coordinators, nursing staff, and therapy teams to review changes. Be sure to download a copy of the ICD-10 Crosswalk: HERE
3. Update Policies and Procedures: Revise documentation protocols to reflect new coding and assessment standards.
4. Coordinate with IT and EHR Vendors: Ensure your electronic health record systems are updated to accommodate new item codes and definitions.
5. Monitor Compliance: Establish internal audits to verify accurate implementation of RAI v1.20.1 changes.

Conclusion

The RAI Manual v1.20.1 introduces meaningful changes that impact clinical documentation, coding accuracy, and regulatory compliance. Ensure your teams are prepared for the October 1, 2025 implementation. By staying informed and proactive, facilities can maintain high standards of care, receive appropriate reimbursement, and reflect accurate public reporting—partner with our experts to streamline your implementation. From staff training to accurate coding for reimbursement optimization, we’ll help ensure your facility is compliant, efficient, and prepared.

Landon Hackett, CPA, MSA, Director

Stephanie Fitzgerald, RN, RAC-CTA, Manager

Liz Barlow, RN, CRRN, RAC-CT, DNS-CT, QCP, Senior Consultant