TN--Care Centers Management Consulting, Inc.

On page 22232 of the rule the following it is indicated, "Finally, physician orders were dropped as a qualifier. Because of the lack of specificity and the variable nature of this qualifier, we do not believe that the presence of physician orders is a reliable predictor of resource use." Yet, among the elements that qualify a resident for Special Care High diabetes with injections and physician order changes on 2 or more days. I believe 2 clarrifications may be in order regarding the removal of physician orders. First, In Special Care High, is CMS referring to MDS item N0350 - Insulin (A) Orders for insulin, and when referring to dropping physician orders, item O700 - Physician orders or both? Is it CMS' intention to remove at all physician orders from this category. Second, if it is CMS' intention to leave physician orders as a contributer to the Special Care High Category, then what specific MDS element is actually contributing, which data elememt actually contributes to the Special Care High Category, new MDS item N0350 - Insulin (A) Orders for insulin, or item O700 - Physician orders or both? I think a clarrification may be in order here related to these two issues regarding physician orders.