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Long Term Care 7 min readApril 27, 2026

PDPM Billing: Common Documentation Errors That Cost Skilled Nursing Facilities Thousands

The Patient-Driven Payment Model (PDPM) fundamentally changed how skilled nursing facilities are reimbursed. But many SNFs are still making documentation errors that systematically reduce their PDPM scores - and their revenue. Here are the most common mistakes and how to fix them.

Understating Clinical Complexity on the MDS

The MDS (Minimum Data Set) assessment drives PDPM classification. When clinicians understate comorbidities, functional limitations, or cognitive impairment, the resulting PDPM score - and reimbursement - drops.

Common examples: not documenting all active diagnoses, understating depression severity, or missing cognitive impairment indicators that would increase the SLP and nursing components.

Timing Errors on Section GG

Section GG (Functional Abilities and Goals) must be completed within a specific window. Assessments done too early or too late don't capture the patient's true functional status at the relevant point in their stay, often resulting in a lower score.

Fix: Standardize assessment timing protocols and use automated reminders tied to admission dates.

Missing or Incorrect Primary Diagnosis Mapping

PDPM maps the primary diagnosis to a clinical category that determines the base payment rate. If the primary diagnosis on the MDS doesn't match the most clinically appropriate (and highest-reimbursing) category, the facility leaves money on the table.

Fix: Review primary diagnosis selection against the PDPM clinical category crosswalk before finalizing each MDS.

SLP Component Underutilization

The Speech-Language Pathology component is one of the most under-documented areas of PDPM. Many facilities miss cognitive-communication disorders, swallowing difficulties, or voice impairments that would qualify for a higher SLP classification.

Fix: Train SLPs to document all assessable conditions, not just the primary reason for referral.

Failure to Reassess When Conditions Change

Interim Payment Assessments (IPAs) allow facilities to update the PDPM classification when a patient's condition changes significantly. Many facilities don't trigger IPAs when they should, missing opportunities to capture higher reimbursement for increased clinical needs.

Fix: Implement a clinical change monitoring protocol that flags conditions warranting an IPA.

How Pono Helps

Pono's MDS-to-claim auditing automatically compares documentation against PDPM scoring rules, flagging underscored categories and missed IPA opportunities before claims are submitted.

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