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Part 2 - Section GG Expansion to OBRA Assessments July 1, 2021

July 28, 2021
Compliance, Documentation, Billing, & Coding By Kay Hashagen, Senior Consultant

In part 1 of this blog series, we discussed the new ruling concerning the Section GG coding requirement on OBRA assessments in Pennsylvania, effective July 1, 2021. This blog will focus on additional details and Frequently Asked Questions related to the directive.


nurse coding


What Should I Remember About OBRA Section GG Requirements?

  • When completing Section GG for Medicare Part A, at least one goal must be completed. For the OBRA assessment, no goals are required.
  • Section GG is not required on stand-alone OBRA discharge assessments.
  • The OBRA Health Insurance Prospective Payment System (HIPPS) code is only four characters. The modifier/assessment indicator (the fifth character in the Medicare Part A Patient-Driven Payment Model (PDPM) HIPPS coding) will not be added to the standalone OBRA assessments.

What Error Messages Will Be Reported on Validation Reports if Section GG Isn’t Completed?

  • Missing Section GG coding on OBRA assessments will be a non-fatal error. Code 3967 WARNING will be provided if A031B equals 99 and your state is actively collecting the PDPM HIPPS code for OBRA assessments. The ICD-10 code submitted in I0020B must also be a valid code defined in the MDS 3.0 Data Submission Specifications. The ASAP system cannot calculate a HIPPS code to validate the submitted Z0100A value.
  • 3921b2, c927B2, or 3942b2 error codes on a validation report are FATAL errors based upon an Invalid Skip Pattern. This code informs the community that your state is actively collecting Section GG data and you have skipped entering information in Section GG in the Minimum Data Set (MDS) or into J2100 for recent surgery.
  • Dashes should not be used unless there is no information, which is a rare occurrence. Implementing systems to guide nurses and therapists to complete Section GG assessments and document the results for OBRA assessments.
  • However, if there is no information to support Section GG, the use of a dash for stand-alone assessments will not have an effect on the SNF-QRP Quality Measures and/or Annual Payment Update (APU).

What Are Some Recent Frequently Asked Questions Related to Section GG for OBRA?

Question: Can the primary diagnosis code change from one OBRA assessment to the next?

Answer: Yes, since you code the primary diagnosis that requires continued nursing care at the time of the assessment, the code may change depending on what is going on with the resident.

Question: What happens if the OBRA assessment is combined with a Prospective Payment System (PPS) 5-Day assessment? What Section GG assessment period dates should be used?

Answer: Whenever assessments are combined, the coding instructions for the PPS assessment are followed. In this scenario, the Section GG assessment period would be the first three days of the admission.

Question: Will there be any updates to the Resident Assessment Instument (RAI) Manual coming soon?

Answer: There are no changes to the RAI Manual scheduled at this time.

How Can LWCI Help?

  • LWCI provides customized knowledge assessments and training for your IDT on the Section GG.
  • LWCI performs pre- and post-bill coding audits in conjunction with MDS mentoring.


If you have questions regarding OBRA Assessments, MDS, PDPM, or other NF-related policies and procedures, contact Kay Hashagen at (410) 777-5999 or email

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