Subchapter M0120 - page 7 -- Good change (Agreed.)
Subchapter M1410 Page 2a - Community Living and other waivers are VERY different than private pay Assisted Living. Be careful with this wording.
Subchapter M1420 Pages 2 and 3 - MDS has been part of this process for a REALLY long time. Local workers are still not getting RUG scores from the facilities. If we are to calculate the RUG score for a client to determine a prospective MNSD - the RUG needs to be readily available. When entering this for a client we have to often stop what we are doing and set the client's change aside to contact the facility (hope they call back) and ask for the current RUG rates. (I would like to suggest that you provide the local agencies (via the manual) with a RUG Rate standard instead of an individualized number. The volume of work doesn't allow for workers to do all this calling around.)
All others are not significant enough to comment - only catching up the manual to PHE rules already in place.