MDS 3.0 — Section I

Active diagnoses,
decoded.

Everything you actually need to know about coding Section I — for new admits, quarterlies, and those “is this even active?” questions that keep you up at night.

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01 — What Is Section I

It’s not a diagnosis dump.

This is the single most important mindset shift for Section I.

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Section I ≠ Copy-paste the H&P. The H&P is a starting point, not the answer. Every single diagnosis on that list must be evaluated before it goes into your MDS. Physicians often carry decades of PMH on an H&P. Most of it does not belong in Section I.
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What Section I actually captures
Per CMS RAI Manual, Chapter 3, Section I

Section I records active diagnoses that have a direct relationship to the resident’s:

⚡ Current functional status
🧠 Cognitive status
😔 Mood or behavior status
💊 Medical treatments or nursing monitoring
☠ Risk of death during the lookback
📊 PDPM clinical category placement
The two-part test

A diagnosis belongs in Section I if and only if it passes both of these:

Documented by a physician, PA, or NP in the medical record within the last 60 days before the ARD
Actively affecting care — being treated, monitored, or contributing to the resident’s clinical picture during the assessment period
✓ Code it
  • Hypertension with active antihypertensives
  • Diabetes managed with insulin or oral agents
  • CHF with active diuretics + fluid monitoring
  • Depression on an SSRI with active monitoring
  • Atrial fibrillation on anticoagulation
  • COPD with active bronchodilators or O₂
  • CKD with labs being monitored
  • Dementia actively affecting ADLs or behavior
✗ Do NOT code
  • “History of appendectomy” — resolved, no active treatment
  • Remote stroke with zero residual deficits
  • Old UTI that resolved last quarter
  • “History of MI” with no current cardiac treatment
  • Childhood asthma not being managed now
  • Resolved C. diff (no active treatment/monitoring)
  • Any dx last documented by a physician >60 days ago
  • Diagnoses documented by nursing only (not MD/PA/NP)
02 — The Active Standard

What does “active” actually mean?

CMS never fully defines “active,” which is why this section trips up so many coders. Here’s how to think about it.

The 60-Day Documentation Rule

A physician, PA, or NP must have documented the diagnosis in the medical record within 60 days before the ARD. This doesn’t mean diagnosed in the last 60 days — it means a qualified provider referenced or addressed it within that window.

Acceptable sources: H&P, progress notes, discharge summary, orders, consultation notes. Not acceptable: nursing assessments, care plans written only by nursing, or verbal reports.

Lookback period nuance
New admit vs. ongoing resident
New Admit (5-Day PPS / OBRA Admission)

The standard assessment lookback is 7 days, but for Section I on a new admit, you’re establishing a baseline. The H&P, hospital discharge summary, and admission orders are your primary sources. These documents carry the physician’s clinical attestation and support your coding as long as the condition is current.

Quarterly / Annual Assessment

The 7-day lookback still applies for the assessment period, but Section I reflects conditions active at any point in the 60 days before the ARD. You’re checking what’s currently being managed — not just what happened in the last week.

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The “affecting care” test
When you’re unsure if something is truly active

Ask yourself: “Is this diagnosis causing something to happen in this resident’s care right now?” Any YES answer to the following means it’s likely active:

There’s a medication on the MAR that treats this condition
Vitals, labs, or assessments are being monitored because of it
It’s limiting what the resident can do functionally
A dietary restriction or special diet is ordered because of it
The physician addressed it in a progress note this month
It’s the reason they were admitted or the reason for a treatment
Nursing care plans address it (with corresponding MD documentation)
Therapy is addressing it (e.g., PT for Parkinson’s gait)
03 — Sources for Diagnoses

Where to actually find your diagnoses

Work through these sources in priority order. The further down the list, the more you need to corroborate with a physician-authored document.

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H&PGold standard — physician-authored, admits current conditions. Still requires the active filter.
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Discharge SummaryHospital-issued, typically current. Great for new admits. Lists active problems at discharge.
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Physician Progress NotesBest ongoing source for quarterlies. Problem lists, SOAP notes, and visit notes all qualify.
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MAR / Medication ListUse to identify conditions that should be present. Every med needs a diagnosis — work backwards.
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Physician OrdersOrders often carry diagnoses. “Lisinopril for HTN” — that’s an MD-attributed diagnosis right there.
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Consult NotesCardiology, neurology, nephrology — specialists often clarify or add diagnoses.
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Lab ResultsSupportive only. Abnormal labs alone don’t make a diagnosis — need physician attribution.
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Prior MDSUseful reference for transfers or readmits. Do NOT auto-carry — each assessment is independent.
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Nursing-only documentation does not count. If the nursing assessment mentions “hypertension” but there’s no physician documentation supporting it, you cannot code it in Section I. When in doubt, query the physician.
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MAR reverse-engineering is your best audit tool. Pull the medication list and ask: “What diagnosis justifies this medication?” If lisinopril is on the MAR and there’s no HTN or CHF coded in Section I, something is wrong. This technique catches both over- and under-coding.
04 — New Admit Workflow

New admit: building from scratch

For a 5-Day PPS or OBRA Admission assessment, you’re establishing the clinical baseline. This is your most important MDS for PDPM — get Section I right and you protect your PDPM category from day one.

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Step-by-step new admit workflow
Complete in this order for maximum accuracy and audit protection
  1. 1
    Read the H&P top to bottomDon’t just skim the problem list. Read the assessment and plan. Physicians sometimes note active conditions in the body that don’t appear in the problem list. Highlight every diagnosis mentioned as current or ongoing.
  2. 2
    Read the hospital discharge summaryThe “active problems” or “discharge diagnoses” section is your best structured list. The hospital physician has already organized what was active at discharge. Use this to cross-check the H&P.
  3. 3
    Pull the admission MARList every medication. For each one, identify the indication. If the indication is a diagnosable condition, it needs physician documentation to support it. Flag any medication without a clear corresponding diagnosis in the chart.
  4. 4
    Review physician admission ordersAdmission orders often include diagnoses (e.g., “Admit for skilled PT/OT. Diagnoses: Hip fracture, DM2, HTN, CHF”). These are physician-attributed and fully valid for Section I.
  5. 5
    Apply the two-part test to every candidate diagnosisFor each diagnosis from steps 1–4: Is it documented by MD/PA/NP? Is it actively affecting care? If both yes → code it. If no on either → do not code without clarification.
  6. 6
    Query the physician for gaps and ambiguitiesMedications without documented diagnoses, vague terms like “altered mental status” or “weakness,” and any condition that seems active but isn’t explicitly documented — all of these need a physician query before the MDS is locked.
  7. 7
    Check for PDPM-relevant diagnosesSection I directly affects PDPM clinical categorization. Conditions like septicemia, respiratory failure, or major surgical wounds need to be specifically documented. Don’t miss high-value diagnoses that change your payment category.
  8. 8
    Code and document your sourcesKeep a working document showing which diagnoses you coded and what source supported each one. This is your audit trail if CMS or the RAC comes knocking. “H&P dated 3/15, Dr. Smith — HTN, active on lisinopril” is all you need.

The “H&P List of 30 Diagnoses” problem

Physicians, especially hospitalists, routinely carry decades of PMH in their H&P problem lists. You’ll see things like “GERD,” “s/p cholecystectomy 1987,” “seasonal allergies,” and “remote DVT 2009” listed alongside active conditions.

Apply the filter to every single one. “GERD” is only active if they’re on a PPI for it and a physician has recently referenced it as current. “S/p cholecystectomy” is historical — never active. You’re not trying to capture the person’s entire medical history. You’re capturing what’s happening clinically right now.

05 — Quarterly Assessment

Quarterly: maintain, update, verify

The biggest mistake on quarterlies is treating Section I like a carry-forward from the last assessment. It isn’t. Every quarter is an independent look at what’s currently active.

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Do not auto-carry diagnoses from previous MDS assessments. CMS expects each assessment to independently reflect current clinical status. Carrying forward conditions that are no longer active is a coding deficiency that can be cited (F640/F641).
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Quarterly workflow
For each quarterly or annual assessment
  1. 1
    Pull the prior MDS Section I as a reference listDo NOT use it as your answer. Use it as a checklist to verify — for each item that was coded, confirm it’s still active. For any condition you’re removing, document why.
  2. 2
    Review physician progress notes from the past 60 daysHas the physician recently addressed each diagnosis? If HTN was last mentioned 75 days ago, you may need a current note before you can code it again.
  3. 3
    Review the current MARAny medication changes? A discontinued medication may mean the corresponding diagnosis is no longer active. A new medication may indicate a new diagnosis that wasn’t in the previous MDS.
  4. 4
    Check for interval eventsHospitalizations, ER visits, new consults, significant change in status — any of these could add new diagnoses or change the status of existing ones.
  5. 5
    Identify diagnoses to removeAny condition that resolved, was no longer documented by a physician in the last 60 days, or is no longer being treated/monitored should be removed. Document your reasoning.
  6. 6
    Identify diagnoses to addNew conditions diagnosed since the last assessment, new diagnoses from hospitalizations, conditions that were always present but previously under-coded (query the physician to get the documentation in the chart first).
  7. 7
    Physician query if neededAny ambiguous or undocumented diagnoses need a query before the ARD locks. Don’t make the same mistake twice — query early.
Chronic — typically stays

These rarely drop off because they’re lifelong and continuously managed:

HypertensionType 2 DiabetesAtrial FibrillationCHFCOPDCKDHypothyroidismHyperlipidemiaDementiaCADParkinson’sEpilepsy

Still requires physician documentation within 60 days of ARD. Don’t assume — verify.

Episodic — may drop off

These are time-limited or resolving — reassess each quarter:

UTIPneumoniaSepticemiaWound infectionDVT (acute)PE (acute)DeliriumPost-op conditionAcute fractureCancer in remission

Once resolved and treatment complete, remove from Section I at next assessment.

06 — Validation Decision Tree

The three questions before you code anything

Run every candidate diagnosis through this decision logic before it hits your MDS.

Question 1: Is this documented by a physician, PA, or NP?
YESProceed to Question 2. The documentation must be in the medical record (H&P, progress note, discharge summary, order, or consult note).
NODo not code. Submit a physician query to get the diagnosis formally documented before the ARD. “Nursing noted the resident has a history of ___” is not sufficient.
Question 2: Is the documentation within the last 60 days before the ARD?
YESProceed to Question 3.
NODo not code without a current note. Options: (1) obtain a current physician note addressing the diagnosis before the ARD, or (2) do not code it and note the documentation gap. Exception: for new admits, the H&P and discharge summary from the admission hospitalization are valid even if technically >7 days old.
Question 3: Is this diagnosis actively affecting the resident’s care, treatment, monitoring, function, or safety right now?
YESCode it in Section I. Document your source and rationale in your MDS notes.
NODo not code. Historical or inactive diagnoses belong in the clinical chart, not Section I. If unsure, query the physician: “Is this condition currently active and affecting care?”
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Common diagnosis coding scenarios
Real examples, practical answers
ScenarioCode it?Why
HTN listed on H&P, patient on lisinopril dailyYESActive treatment, physician-documented, ongoing
“History of MI” — no cardiac meds, no monitoringNOHistorical only; no active treatment or monitoring
MI 3 years ago, currently on aspirin + statin + metoprololYESCAD/post-MI actively managed — code the active dx driving the meds
Dementia — affecting ADLs, behavior, and supervision needsYESActively affecting function; must have MD diagnosis in chart
UTI resolved last month, currently no antibiotics or symptomsNOResolved episodic condition; do not carry forward
CKD Stage 3 — labs monitored quarterly, on dietary restrictionYESActive monitoring and dietary management = active
Septicemia from admission, now resolved on this quarterlyNOWas active on the admission MDS, not on this quarterly
“Weakness” or “failure to thrive” without specific MD dxQUERYNeed a specific physician-attributed diagnosis; query before coding
Depression — on sertraline, physician monitoring mood quarterlyYESActive treatment and monitoring; code it
Old stroke (5 years ago) with residual left hemiplegia affecting ADLsYESResidual deficits actively affecting function; physician must document sequelae
Type 2 DM — A1c controlled, no meds, diet-controlled onlyYESActive dietary management; physician monitors A1c = active
Cancer in remission, no treatment, last oncology note 4 months agoQUERYNo active treatment + documentation gap >60 days; need current provider note
07 — When Diagnoses Drop Off

Yes — diagnoses do drop off

The MDS isn’t a permanent medical record — it’s a snapshot of current clinical status. Diagnoses fall off when the clinical reality changes.

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When to remove a diagnosis from Section I
Any ONE of these is sufficient reason to drop it
The condition has resolved

UTI cleared, pneumonia resolved, acute DVT treated with no ongoing anticoagulation planned, wound healed, post-op condition resolved. Once resolved and no longer affecting care, it’s off.

No physician documentation in the past 60 days

Even for chronic conditions. If the physician’s last mention of “hypothyroidism” was 90 days ago, you cannot code it without getting a current note. Easily fixed with a brief physician query.

Treatment has permanently stopped and monitoring ceased

If a medication was discontinued, the corresponding condition is no longer being treated. Unless the physician still documents it as active (e.g., DM managed by diet alone), it may not meet the active threshold.

Diagnosis was initially uncertain and has been ruled out

“Rule out dementia” that was worked up and turned out to be delirium. Once the physician has a clearer picture, update accordingly.

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For long-term residents with stable chronic disease: The issue is usually the documentation gap — the physician saw the patient 3 months ago and didn’t mention CHF because everything was stable. Get a monthly physician note template that includes a brief problem list review. Solves 80% of your Section I documentation headaches.
08 — Common Mistakes

What gets facilities cited

These are the Section I errors that show up in F640, F641, and F644 surveys.

Mistake 01

Blanket carry-forward from prior MDS

Opening the last MDS, hitting “carry-forward” on Section I, and calling it done. Surveyors compare assessments. If the same 14 diagnoses appear verbatim across 3 years of quarterlies with no variation, that’s a red flag for rubber-stamping.

Mistake 02

Coding diagnoses supported only by nursing documentation

The nursing assessment says “resident has a history of bipolar disorder” but there’s no physician note in the chart attributing it. This is a documentation deficiency. You cannot code it and CMS can cite you for inaccurate MDS completion (F641).

Mistake 03

Leaving active diagnoses off the MDS

Under-coding is just as problematic as over-coding. If a resident is on warfarin for afib and you haven’t coded atrial fibrillation, that’s a Section I error. Under-coding also suppresses PDPM payment and affects quality measures.

Mistake 04

Using “rule out” diagnoses as confirmed

“R/O Parkinson’s” is not the same as a Parkinson’s diagnosis. Do not code unconfirmed conditions. Query the physician: “Has this diagnosis been confirmed or ruled out?”

Mistake 05

Not knowing the Section I item coding nuances

Some items in Section I have specific CMS definitions that differ from general clinical use:

I2000 — Kidney Disease: Code CKD stages 1–4 here. Stage 5 / ESRD goes to I2100. Many coders miss the distinction.
I4200 — Alzheimer’s Disease: Requires a specific Alzheimer’s diagnosis, not just “dementia.” Different dementias code differently.
I8000 — Other Diagnoses: Use for active conditions not covered by specific items above. Many facilities under-use this item.
Mistake 06

Skipping Section I on Significant Change assessments

A SCSA requires a full MDS including a fresh Section I. When someone is hospitalized, has a new major diagnosis, or has a significant clinical decline, the new assessment must reflect the updated clinical picture.

09 — Physician Query Templates

Query templates that actually get answered

Keep these short, specific, and clinical. Physicians respond to queries that tell them exactly what you need and why it matters. Never ask vague questions.

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Query before the ARD, not after. Once the MDS is locked, correcting Section I requires a modification. Get your queries submitted at least 3–4 days before the ARD closes so you have time to get the response and incorporate it.
Template 01 — Confirm Active Diagnosis
“Dr. [Name], I am completing the MDS for [Resident] with an ARD of [date]. I note [CONDITION] is listed in the chart. Could you please confirm in a progress note whether this condition is currently active and affecting [his/her] care, and if so, what treatment or monitoring is in place? This documentation will support accurate MDS coding.”
Template 02 — Medication Without a Coded Diagnosis
“Dr. [Name], [Resident] is currently on [MEDICATION]. For MDS accuracy, I need a documented diagnosis that this medication is treating. Could you please update your progress note or medication list to include the associated active diagnosis?”
Template 03 — Diagnosis Specificity Needed
“Dr. [Name], the chart documents [VAGUE TERM — e.g., ‘dementia,’ ‘kidney disease’]. For MDS coding accuracy and PDPM, I need the most specific diagnosis possible. Could you please clarify the type/stage/specificity in your next note? For example: Alzheimer’s vs. vascular dementia; CKD Stage 3 vs. ESRD.”
Template 04 — Condition Not Documented in 60 Days
“Dr. [Name], [Resident’s] MDS assessment window requires active diagnosis documentation within 60 days. Your last documented reference to [CONDITION] was on [DATE]. To accurately reflect this condition on the current MDS (ARD: [DATE]), could you please briefly reference it in your next progress note, including whether it remains active and how it is currently being managed?”
Template 05 — Confirm Resolved Condition
“Dr. [Name], [Resident] was previously treated for [CONDITION]. As of this quarterly assessment, I do not see active treatment or monitoring in place. Could you confirm in a brief note whether this condition has resolved and can be removed from the active problem list, or whether it remains clinically relevant?”
Quick Reference

Section I — At a glance

Core rules
Must be documented by MD/PA/NP
Documentation within 60 days of ARD
Must be actively affecting care
Not historical/resolved conditions
Not “rule out” diagnoses
Each assessment is independent
Key sources
H&P (primary for new admits)
Discharge summary
Physician progress notes
MAR (reverse-engineer to diagnoses)
Physician admission orders
Consult notes
Before you lock the MDS
Every dx has a physician source?All sources within 60 days?Every active condition coded?Resolved conditions removed?Physician queries submitted?MAR cross-referenced?I8000 used for anything not listed?PDPM-relevant dx captured?

Source: CMS RAI User’s Manual v1.18.11, Chapter 3, Section I — Active Diagnoses. Written by Jayson Minagawa, BSN, RN, Unit Manager & MDS Coordinator.