01/15/2026

You Asked... We Answered

You Asked: Can Certified Nursing Assistants (CNA) documentation be used to validate Section GG coding during an MDS exception review?

We Answered: The Ohio Department of Medicaid has provided a Section GG Functional Performance Fact Sheet that addresses supporting documentation. ODM states the following about direct care staff and qualified clinician documentation.

The requirements for Section GG come with significant changes for the Activities of Daily Living (ADLs) and tracking for functional or reporting purposes. The previously utilized ADL flow sheets completed by the Certified Nursing Assistants (CNAs) will no longer be functional to align with Section GG. If CNAs are going to do the data collection of Section GG there will need to be training. Direct care staff must understand each task definition and the performance scale. The Resident Assessment Instrument (RAI) user’s manual defines each activity and sets forth the steps for completing the assessment.

Please note: Direct care staff will not determine “usual” performance. Direct care staff documents actual performance during the episode/shift and qualified clinician will determine “usual” performance after reviewing documentation from the 3-day performance period.