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Bridging the Gap: Turning Section GG Accuracy into Better Outcomes

On August 20, 2026 by LeadingAge Minnesota

Section GG has become one of the most influential sections of the Minimum Data Set (MDS), yet it remains one of the most misunderstood. While many clinicians recognize its importance for Medicare reimbursement, Section GG extends far beyond payment. Accurate coding directly impacts Quality Measures, Value-Based Purchasing, Five-Star performance, state Medicaid case-mix systems, discharge planning, and the resident's overall clinical story.

Despite its significance, many skilled nursing facilities continue to experience inconsistent GG coding—not because staff lack clinical knowledge, but because processes, communication, and education often fail to keep pace with evolving expectations. The encouraging news is that most of the opportunities for improvement are operational and can be addressed through standardized workflows and interdisciplinary collaboration.

Coding Usual Performance, Not Best or Worst

One of the most common challenges is determining the resident's usual performance. Section GG requires facilities to code the resident's typical level of function during the assessment period, not the resident's best or worst performance. A resident recovering from surgery or a stroke may require substantial assistance one day and only supervision the next. Selecting the highest or lowest level of function instead of identifying the resident's usual performance can significantly alter reimbursement and quality outcomes.

Observation, Not Assumption

Another frequent opportunity involves relying on assumptions rather than observation. Staff may unintentionally code what they believe a resident is capable of doing instead of what actually occurred. Section GG should always reflect observed performance supported by interdisciplinary documentation from nursing, therapy, and certified nursing assistants. Every member of the care team contributes valuable information that helps paint an accurate picture of the resident's functional abilities.

Selecting the Correct Level of Assistance

Facilities also continue to struggle with selecting the correct level of helper assistance. Distinguishing between setup assistance, supervision, partial assistance, substantial assistance, and dependent can be challenging without ongoing education. These distinctions may appear minor, but even a one-level difference can affect quality metrics and reimbursement. Routine competency training using real resident scenarios helps improve consistency and confidence among staff responsible for documenting functional performance.

Appropriate Use of "Not Attempted" Codes

The use of "Not Attempted" codes presents another opportunity for improvement. Codes such as 07, 09, 10, and 88 should only be used when the specific RAI Manual definitions are met and supported by documentation. These codes should never become the default option simply because an activity was not observed during a shift. Clear documentation explaining why an activity was not attempted is essential to support accurate coding and withstand audit scrutiny.

Communication Across Disciplines

Perhaps the greatest opportunity lies in improving communication across disciplines. Section GG should never be viewed as solely a therapy responsibility or an MDS responsibility. The highest-performing organizations recognize that accurate functional coding depends on collaboration between nursing, therapy, restorative nursing, MDS coordinators, and clinical leadership. When each discipline contributes its observations, the resulting GG coding more accurately reflects the resident's true functional status.

The Value of Daily Clinical Meetings

Daily Medicare or PDPM clinical meetings have proven to be one of the most effective strategies for improving GG accuracy. These brief interdisciplinary discussions allow the team to review recent functional changes, identify documentation gaps, confirm usual performance, and ensure coding decisions align with the resident's clinical presentation before the assessment is finalized. Addressing questions concurrently is significantly more effective than attempting to reconstruct the resident's performance days later.

Regular Auditing as a Bridge

Regular auditing is another valuable tool for bridging the gap. Reviewing completed GG coding alongside supporting documentation often reveals patterns that can be addressed through targeted education. Rather than viewing audits as compliance exercises, successful organizations use them as opportunities to coach staff, strengthen documentation practices, and improve consistency across departments.

The Benefits of Getting It Right

The benefits of accurate Section GG coding extend well beyond regulatory compliance. Facilities that prioritize functional accuracy often experience more appropriate Medicare reimbursement, stronger state Medicaid case-mix classifications where applicable, improved Quality Measure performance, better Value-Based Purchasing outcomes, and stronger Five-Star ratings. Equally important, accurate coding supports safer discharge planning by ensuring care teams clearly understand the resident's functional abilities and ongoing needs.

Telling the Resident's Story

At its core, Section GG is about telling the resident's story accurately. Every transfer, every walk to the bathroom, every meal completed independently, and every improvement achieved through skilled care contributes to that story. When documentation and coding truly reflect the resident's usual performance, facilities are rewarded with more accurate reimbursement, stronger publicly reported outcomes, and greater confidence during audits.

Bridging the gap in Section GG does not require coding residents higher or lower—it requires coding them correctly. By investing in interdisciplinary collaboration, standardized processes, concurrent reviews, and continuous education, skilled nursing facilities can transform Section GG from a documentation requirement into a powerful driver of clinical excellence, financial stewardship, and quality outcomes.

When organizations focus on coding accuracy instead of simply coding completion, everyone benefits. Residents receive care that reflects their true functional needs, clinicians gain confidence in the assessment process, leadership obtains more reliable quality data, and facilities are better positioned to thrive in an increasingly outcome-driven healthcare environment. In today's skilled nursing landscape, accurate Section GG coding isn't just best practice, it's a strategic advantage.