The importance of accurate coding of section GG, Functional Abilities, continues to grow as this data is used in care planning, Quality Measures, reimbursement, and regulatory compliance. The Centers for Medicare & Medicaid Services (CMS) released the final RAI User’s Manual, v1.20.1, in late August. It includes several clarifications for section GG. This article identifies four key strategies to help nurse assessment coordinators (NACs) refocus on section GG and prepare the staff for the Oct. 1, 2025, updates.
Strategy 1: Use the entire 3-day assessment time frame for data collection when able
The updated manual provides this new general coding tip on page GG-17: “The assessment timeframe is up to 3 calendar days based on the target date. During the assessment timeframe, some activities may be performed by the resident multiple times, whereas other activities may only occur once.” Thus, to assess the resident’s usual performance accurately, the team must consider all of the tasks across the 3-day window. This instruction aligns with the current coding tip (p. GG-20, v1.19.1), requiring that the “activity not attempted” codes only be used if the “resident does not attempt the activity and a helper does not complete the activity for the resident during the entire assessment period.”
A coding tip added to page GG-12 emphasizes that the task can be completed with or without assistive devices and the performance must be assessed even if the activity is not performed routinely. The tip offers these examples: “walking might be assessed for a resident who did/does/will use a wheelchair as their primary mode of mobility, stair activities might be assessed for a resident not routinely accessing stairs.”
Collecting functional ability documentation from the entire 3-day assessment period ensures that (1) all recorded episodes of care are considered when determining usual performance, and (2) “activity not attempted” codes are not used if the task occurs at least once. This guidance also reinforces why it is vital to document the performance each time a task is completed during the assessment window. Establishing a process to communicate when residents are in this narrow 3-day window and checking with direct care staff during that time to better understand the resident’s performance will result in strong documentation to support usual performance.
Strategy 2: Apply new section GG coding rules
The final RAI User’s Manual lists the following new coding tips to share with all staff completing supporting documentation.
Eating: CMS clarifies that the “adequacy of the resident’s nutrition or hydration is not considered for GG0130A, Eating” (p. GG-28). This explanation reminds direct care staff that they must remain focused on how the resident performs the task of eating meals.
Putting on and taking off footwear: On page GG-28, assessors are instructed to consider an item “that covers all or part of the foot as footwear, even if it extends up the leg, and do not also consider it as a lower-body dressing item.” This instruction is a key reminder for direct care staff who help dress residents.
Walking: In the updated manual, CMS instructs staff how to code “dependent” while a resident walks. The current manual states that the “walking activity cannot be completed without some level of resident participation that allows resident ambulation to occur for the entire stated distance. A helper cannot complete a walking activity for a resident.” This instruction may have been interpreted incorrectly to mean a resident cannot be coded as “dependent” for walking. The manual clarifies this requirement: “If the resident who participates in walking requires the assistance of two helpers to complete the activity, code 01, Dependent” (p. GG-51).
Stairs: For the steps/stairs items, the final manual emphasizes the instruction (p. GG-56) “getting to/from the stairs” or the resident’s ability to move from “sit-to-stand or stand-to-sit transfer when coding any of the step activities.” The NAC should include this information when training therapy team members, who will likely be the clinicians assessing this ability of the resident. This essential instruction separates the distinct individual tasks assessed in section GG.
Strategy 3: Use clinical judgment in the assessment process
CMS emphasizes on page GG-39 of the updated manual that clinical judgment should be used to decide if certain GG tasks are completed. CMS added, “For GG0170A, Roll left and right; GG0170B, Sit to lying; and GG0170C, Lying to sitting on side of bed, clinical judgment should be used to determine what is considered a ‘lying’ position for the resident. For example, a clinician could determine that a resident’s preferred slightly elevated resting position is ‘lying’ for a resident.”
In the current manual, CMS also instructs the assessor to use clinical judgment when determining how the walking assessment is conducted, when coding individual tasks were completed sequentially, deciding what ground is considered uneven, and noting if the resident uses the wheelchair for self-mobilization.
When clinical judgment is used to evaluate usual performance for a resident, the chosen rationale should be documented in the medical record to support the final coding decision. Working with a team of qualified clinicians to identify usual performance and make these clinical judgment decisions helps ensure a collaborative approach to assessing the resident’s functional status and creating an individualized care plan.
Strategy 4: Apply all the rules
One of the new coding tips in the manual (p. GG-51) states, “If two or more helpers are required to assist the resident in completing the activity, code as 01, Dependent.” The AAPACN team submitted a question to CMS regarding this tip, asking how it should be applied to identify usual performance. The team expressed concern that the tip could mean that regardless of how the resident usually performed during the 3-day window, if two or more helpers were required at any time, the assessor would code 01, Dependent, for this task. CMS replied, “The MDS 3.0 RAI User’s Manual contains guidance and coding tips regarding usual performance, which are applicable for Section GG. The single coding tip you have identified is not mutually exclusive and should not be applied over and above the guidance for determining usual performance.”
This response reinforces the overall objective of section GG and also dispels some common misconceptions. When coding the MDS, all coding instructions, guidance, and tips must be considered as a whole. Individual coding tips should not be taken out of context to change the intent of the assessed item.
Conclusion
As section GG continues to evolve, NACs must stay current with both long-standing guidance and the upcoming clarifications in the v1.20.1 RAI User’s Manual. The four strategies described in this article—using the full 3-day assessment period, applying updated coding rules, using clinical judgment, and ensuring all coding guidance is considered collectively—are essential for accurate and defensible coding. With the Oct. 1, 2025, updates approaching, now is the time to refocus training, strengthen documentation processes, and reinforce interdisciplinary collaboration to support high-quality compliant functional assessments.
References
Centers for Medicare & Medicaid Services (CMS). (2025). Long-term care facility resident assessment instrument 3.0 user’s manual, version 1.20.1. https://www.cms.gov/files/document/finalmds-30-rai-manual-v1201october2025.pdf-0.
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