Our contacts at the Texas Department of Aging and Disability Services (DADS) have asked us to pass along some important reminders about proper PL1 submissions. These guidelines will help you understand what to do in the case of a resident death or discharge, and help you be sure your PL1 is not submitted late.

In recent PASRR record reviews, DADS has noticed a large number of cases where facilities have incorrectly entered PL1s far past the time where a resident has passed away or has been discharged (in some cases as much as three months later).

In this type of situation, PL1s submitted as “Positive” will trigger an alert to the Local Authority (LA). The status shows “Awaiting PE,” which makes it appear that the resident is still in the facility and that the Local Authority hasn’t fulfilled its responsibilities.

In addition to creating the potential for citation, submitting the PL1 late can cause issues or delays in submitting your LTCMI.

Guidelines for correct PL1 submissions

Follow these guidelines to ensure your resident’s PL1 is submitted correctly:

1. IMPORTANT: PL1s should be submitted upon admission. PASRR rule 19.2704 states, “A nursing facility must not admit an individual who has not had a PL1 conducted before the individual is admitted to the facility.” However, the interruptive guidelines mean the form must be submitted upon admission. (Note: DADS reports they will be revising the PASRR rule to allow 72 hours to enter the PL1 after admission.)
2. Be sure to complete sections B0650 and B0655 when someone passes away or discharges on your positive PL1s. For now, you can enter this information if the PE hasn’t been entered or if the PL1 date is less than 90 days old.
3. If an individual has not had an interruption in continuous nursing facility residence other than for acute care lasting fewer than 30 days and is returning to the same nursing facility, a new PL1 is not needed and there is no need to enter discharge information on the PL1.
4. All other discharges require a new PL1 upon readmission or if the acute care stay exceeds 29 days.

Respite and exempted stays

DADS also noted a number of respite or exempted admissions in the “Awaiting PE” status, but the individual left the facility and the PL1 should have been inactivated:

• For respite, it’s even more important to discharge the PL1 when they go home, as the system will generate an alert on the 14th day and the status will change to “Awaiting PE.” When the individual completes their respite stay, enter the discharge information on section B0650 and B0655. This will inactivate the PL1. If the individual comes back to the NF a new PL1 will need to be done.
• The same is true for 30-day exempted stays. If the individual leaves on or before the 30th day, enter the information on the PL1 to inactivate it, otherwise an alert will be sent to the LA and the status will change to “Awaiting PE.”

Future PL1 enhancements

DADS is working on an enhancement expected for the first quarter of the next fiscal year (Sept. 2016), which will allow you to inactivate the PL1 after the PE has been submitted or past 90 days. This should be a great help to you in cleaning up your PASRR records.

If you have questions or need clarification, please contact the DADS PASRR Unit at (855) 435-7180 or pasrr@dads.state.tx.us.