10/30/2025

Survey Tip of the Week: Significant Change

A Significant Change in Status Assessment (SCSA) is required to be completed within 14 days after a determination has been made that a significant change in the resident’s status from baseline occurred. Citations occur when the facility fails to document in the medical record when the determination is made that the resident meets the criteria for a SCSA, or the facility fails to complete the SCSA timely.

A SCSA is appropriate if there are either two or more MDS areas of decline or two or more MDS areas of improvement and the resident isn’t expected to return to baseline within two weeks or if the IDT determines that the resident would benefit from the SCSA assessment and subsequent care plan revision. The State Operations Manual Appendix PP provides the following guidance on significant change determinations:

A Significant Change in Status MDS is required when:

• A resident enrolls in a hospice program; or
• A resident changes hospice providers and remains in the facility; or
• A resident receiving hospice services discontinues those services; or
• A resident experiences a consistent pattern of changes, with either two or more areas of decline or two or more areas of improvement, from baseline (as indicated by comparison of the resident’s current status to the most recent CMS-required MDS).

Examples of Decline include, but are not limited to:

• Resident’s decision-making ability has changed;
• Presence of a resident mood item not previously reported by the resident or staff and/or an increase in the symptom frequency, e.g., increase in the number of areas where behavioral symptoms are coded as being present and/or the frequency of a symptom increases for items in Section E Behavior;
• Changes in frequency or severity of behavioral symptoms of dementia that indicate progression of the disease process since last assessment;
• Any decline in an ADL physical functioning area (at least 1) where a resident is newly coded as partial/moderate assist, substantial/maximal assistance, dependent, resident refused, or not attempted since last assessment and does not reflect normal fluctuations in that individual’s functioning;
• Resident’s incontinence pattern changes or there was placement of an indwelling catheter;
• Emergence of unplanned weight loss problem (5% change in 30 days or 10% change in 180 days).
• Emergence of a new pressure ulcer at Stage 2 or higher, a new unstageable pressure ulcer/injury, a new deep tissue injury or worsening in pressure ulcer status;
• Resident begins to use a restraint of any type, when it was not used before;
• Emergence of a condition/disease in which a resident is judged to be unstable.

Examples of Improvement include, but are not limited to:

• Any improvement in ADL physical functioning area (at least 1) where a resident is newly coded as Independent, Setup or clean-up assistance, or Supervision or touching assistance since last assessment and does not reflect normal fluctuations in that individual’s functioning;
• Decrease in the number of areas where behavioral symptoms are coded as being present and/or the frequency of a symptom decreases;
• Resident’s decision making ability improves;
• Resident’s incontinence pattern improves. 

The RAI manual provides additional guidance on completion of the SCSA. Facilities should integrate data collection and monitoring of the significant change criteria into their QAPI program.