PDPM Reimbursement: 5 Common Classification Mistakes Costing Your SNF Money

November 19, 2025 12 min read PDPM

Since PDPM replaced RUG-IV in October 2019, skilled nursing facilities have had to master a fundamentally different reimbursement model. Unlike the therapy-driven RUG system, PDPM classifies residents across five separate components—each with its own complexity and potential for error.

After reviewing thousands of MDS assessments, we've identified five classification mistakes that consistently result in lost reimbursement. These aren't rare edge cases—they're systematic errors that affect facilities every day.

Understanding PDPM's Five Components

Before diving into the mistakes, let's review the five PDPM components and what drives each:

  • Physical Therapy (PT): Clinical category and Section GG functional scores
  • Occupational Therapy (OT): Clinical category and Section GG functional scores
  • Speech-Language Pathology (SLP): SLP-related comorbidities, cognitive status, swallowing disorders, and mechanically altered diet
  • Nursing: Clinical category, extensive services, and nursing case mix
  • Non-Therapy Ancillary (NTA): HIV/AIDS, NTA comorbidities, and extensive services

Each component is calculated separately, then combined for the total per diem rate. Missing optimization in any single component reduces overall reimbursement.

Mistake #1: Under-Capturing Comorbidities

This is the single most common—and most costly—PDPM error. The NTA and SLP components rely heavily on ICD-10 diagnosis codes to identify comorbidities that increase payment.

The Error: Failing to capture all qualifying comorbidities from physician documentation, hospital discharge summaries, and nursing assessments.

Common Missed Comorbidities

  • Morbid obesity (E66.01): Often documented but not coded
  • Malnutrition (E43, E44.0, E44.1): Frequently present but under-captured
  • Heart failure (I50.x): May be in history but not on active diagnosis list
  • Aphasia (R47.01): Impacts SLP classification significantly
  • Hemiplegia/hemiparesis (G81.x): Often missed when not primary diagnosis
  • Diabetes with complications (E11.21, E11.22, etc.): Simple diabetes coded instead of complicated

How to Fix It

  • Review ALL available documentation: hospital H&P, discharge summary, consultant notes, nursing assessments
  • Create a comorbidity checklist based on PDPM's specific NTA and SLP lists
  • Query physicians for specificity when diagnoses are vague
  • Don't rely solely on the primary diagnosis—secondary diagnoses often drive NTA payment

Revenue Impact: A single missed NTA comorbidity can significantly reduce reimbursement per day. Over a 20-day stay, that's hundreds to thousands in lost revenue per resident.

Mistake #2: Inaccurate Section GG Functional Scoring

Section GG drives PT and OT classification. Errors in functional scoring directly translate to incorrect reimbursement—both over and under.

The Error: Coding Section GG based on what residents could do rather than what they actually did, or inconsistently applying the coding scale.

Specific Section GG Issues

  • Confusing setup with supervision: Code 05 (setup) means helper leaves; code 04 (supervision) means helper stays
  • Inconsistent "more than half" judgments: The distinction between codes 02 and 03 requires careful observation
  • Coding potential vs. actual: Section GG captures what happened, not what could happen
  • Using wrong items for PDPM: Not all Section GG items affect PDPM equally

Key Section GG Items for PDPM

Focus accuracy efforts on these high-impact items:

  • GG0130A (Eating): Affects OT and SLP components
  • GG0170C (Lying to Sitting): Affects PT and OT components
  • GG0170D (Sit to Stand): Affects PT and OT components
  • GG0170J (Walk 50ft): Affects PT component
  • GG0170K (Walk 150ft): Affects PT component

Related Resource: For comprehensive guidance on Section GG coding, see our Complete Guide to MDS 3.0 Section GG.

Mistake #3: Incorrect Clinical Category Assignment

The clinical category is the foundation of PDPM classification, determining baseline rates for PT, OT, SLP, and Nursing components. Getting it wrong affects every component.

The Error: Selecting clinical categories based on the primary diagnosis alone, without considering the reason for SNF admission.

Clinical Category Determination

PDPM uses ICD-10 codes to assign one of ten clinical categories:

  • Major Joint Replacement or Spinal Surgery
  • Non-Surgical Orthopedic/Musculoskeletal
  • Acute Neurologic
  • Non-Surgical Neurological
  • Acute Infections
  • Cancer
  • Pulmonary
  • Cardiovascular/Coagulations
  • Medical Management
  • Return to Provider

Common Clinical Category Errors

  • Defaulting to Medical Management: This is the lowest-paying category and often used when better options exist
  • Missing surgical windows: Major Joint Replacement has specific timeframes from surgery date
  • Ignoring secondary diagnoses: Sometimes a secondary diagnosis better captures the reason for SNF care
  • Using hospital principal diagnosis: The SNF primary diagnosis should reflect the reason for skilled care, not the hospital stay

Compliance Note: Clinical categories must be supported by the clinical picture. Selecting a higher-paying category without appropriate documentation is a compliance violation.

Mistake #4: Missing Extensive Services

Extensive services significantly increase Nursing and NTA payments, but they're frequently under-captured because they require specific documentation and coding.

The Error: Not capturing extensive services that were provided, or failing to meet documentation requirements for services that were coded.

PDPM Extensive Services

  • Tracheostomy care (while on ventilator): Highest-paying extensive service
  • Ventilator/Respirator: Must meet specific definition and timeframes
  • IV Medications: Must be for something other than nutrition or hydration
  • Isolation for active infectious disease: Must be during assessment period
  • Radiation therapy: Must meet specific requirements

Documentation Requirements

Extensive services require:

  • Physician orders active during the look-back period
  • Documentation of actual service provision
  • Clinical justification for the service
  • Correct coding in Section O of the MDS

Mistake #5: SLP Component Under-Optimization

The SLP component is often overlooked because it involves factors beyond swallowing disorders. Facilities frequently miss optimization opportunities.

The Error: Only focusing on swallowing-related items while missing cognitive and communication factors that affect SLP classification.

SLP Component Drivers

Beyond swallowing disorders, SLP classification considers:

  • Cognitive impairment (BIMS scores): Lower BIMS can increase SLP payment
  • Aphasia: Any aphasia diagnosis increases classification
  • Voice problems requiring SLP: Often present but not captured
  • Mechanically altered diet: Must be properly documented
  • SLP comorbidities: CVA, ALS, Parkinson's, etc.

Frequently Missed SLP Opportunities

  • Residents with dementia: Cognitive components affect SLP classification
  • Post-stroke without swallowing issues: May still have aphasia or cognitive impact
  • Residents on puree/mechanical diets: Diet texture must be accurately captured
  • Residents with voice changes: May require SLP evaluation

Stop Leaving Money on the Table

We built MDS Genie™ to analyze clinical documentation and identify missed comorbidities, optimal clinical categories, and accurate Section GG codes—all in minutes instead of hours. Learn how we can customize this solution for your facility.

Learn About MDS Genie™

Building a PDPM Optimization Process

Avoiding these five mistakes requires systematic processes, not just individual awareness:

1. Pre-Admission Review

Before admission, review hospital documentation to identify:

  • Potential clinical category
  • Documented comorbidities
  • Likely extensive services
  • Expected functional status

2. Interdisciplinary Assessment

Ensure all disciplines contribute to the MDS:

  • Therapy: Section GG functional scores
  • Nursing: Section G ADLs, extensive services
  • Dietary: Mechanically altered diet, nutritional status
  • Social Services: Cognitive status, psychiatric diagnoses

3. Documentation Review

Before finalizing the MDS, verify:

  • All comorbidities from available documentation are captured
  • Clinical category is optimal and supported
  • Section GG scores align with nursing and therapy notes
  • Extensive services are documented and coded correctly

4. Regular Auditing

Conduct monthly audits to identify patterns:

  • Compare facility PDPM distribution to state/national benchmarks
  • Review for systematic under-capture of specific comorbidities
  • Analyze Section GG scoring patterns across staff
  • Track clinical category distribution over time

Summary

PDPM offers significant reimbursement when classified correctly, but the five-component model creates multiple opportunities for error. The five most common mistakes are:

  1. Under-capturing comorbidities: Review all documentation for NTA and SLP comorbidities
  2. Inaccurate Section GG scoring: Code actual performance using correct definitions
  3. Incorrect clinical category: Select based on reason for SNF care, not just primary diagnosis
  4. Missing extensive services: Capture and document all qualifying services
  5. SLP under-optimization: Consider cognitive and communication factors beyond swallowing

Addressing these systematically—through better processes, training, and technology—can recover significant lost revenue while maintaining compliance.

Additional Resources

Let's Discuss Your Operational Challenges

Explore how custom AI solutions can transform your facility operations