In the MDS 3.0 RAI Manual (newest version), CHOWs are addressed on page 2-4 and Transfers of Residents on page 2-5.

There are two types of CHOWs:

  1. The facility accepts assignment (the history and liabilities of the previous owner). The CMS Certification Number (CCN/Medicare Number) and Provider ID/Vendor ID stay the same but the National Provider Identifier (NPI) and Medicaid Contract Number change. MDS are ongoing and the schedule for MDS continues uninterrupted. For example, if the last MDS was an annual assessment, and the next scheduled MDS is a quarterly assessment due next week, the quarterly assessment is to have the correct Assessment Reference Date (ARD) for next week. Ensure that the NPI number in A0100A is correct based on the ARD of the MDS. In other words, staff input the old NPI if the ARD is before the date of the CHOW and the new NPI if the ARD is on or after the date of the CHOW.
  2. The facility does NOT accept assignment (the history and liabilities of the previous owner). The Provider ID/Vendor ID stays the same but the CCN, NPI, and Medicaid Contract Number change. All the residents are discharged from the "old" facility on the date of the CHOW and new Omnibus Budget Reconciliation Act (OBRA) Admission MDS assessments are due within 14 days of "admission" to the new facility (e.g., within 14 days of the CHOW). The new admission MDS assessment, as well as subsequent MDS records that become due, must be completed in a timely manner per the schedule in the RAI Manual, but cannot be transmitted until the new CCN is received from CMS.

In summary, the type of CHOW makes a difference to the MDS schedule but does not stop the clock on performing MDS assessments. Ensure that MDS assessments are being completed appropriately as scheduled. However, if it is a CHOW without assignment, do NOT submit any MDS (tracking records or assessments) for the new facility until you receive both the new NPI and the new CCN. See "Required CMS Certification Number (CCN)" under Step 4: Sign up / Log on to CMS for more information about the CCN and submitting Medicaid records for payment.

When there is a CHOW without assignment, it is recommended that the old owner have at least one person maintain their logon and software settings for the old facility. After the CHOW, there will usually be MDS assessments that will have to be submitted and/or corrected under the old facility. Do not remove all access and software settings for the old facility until there is absolutely no chance that any more MDS assessments will be submitted and/or corrected under the old facility.

Concerned about having a number of assessments due around the same time? Remember that MDS OBRA assessments can be completed early. When resident assessment due dates are bunched together, you can space them out by completing quarterly or yearly assessments earlier than required by the MDS schedule.