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Being MDS Certified or an MDS Certification is Not Required Per Regulation

Updated: Sep 12, 2022

An MDS nurse or MDS coordinator does not have be MDS certified or have an MDS certification in order to start doing MDS assessments! Read on to find out what the actual regulation says.

Before discussing this topic, the terminology used need to be considered. Often times, people mistake a “certificate of completion,” or “certificates” as a “certification” or "certified". Especially when it comes to MDS. There is a huge difference.

Certificate of Completion- "Demonstrates evidence of specialized education achievement. The courses you take in a certificate program could help you prepare to earn a professional field-specific certification, but earning a certificate is not the same as becoming certified." (University of Virginia)

MDS Certificate vs Certification https://

Certification- Usually experience is a prerequisite. "The process of giving official or legal approval to a person, company, product, etc. that has reached a particular standard." (Cambridge Dictionary)

Certified- Gaining a certification makes one certified. Becoming certified involves experience in the field with added designation.

How does the above apply, or not apply, to the MDS process? Knowing the difference determines the MDS class you need.

Do not make the mistake of taking a workshop, training or course to become MDS certified and have MDS certification unless you have experience! Remember, in order to be certified, one is recommended to have experience.

Below are the regulations regarding the MDS process and those involved (Resident Assessment Instrument [RAI] manual version 1.17 pages 1-7 and 1-8):

The RAI process has multiple regulatory requirements. Federal regulations at 42 CFR 483.20 (b)(1)(xviii), (g), and (h) require that

(1) the assessment accurately reflects the resident’s status (2) a registered nurse conducts or coordinates each assessment with the appropriate participation of health professionals (3) the assessment process includes direct observation, as well as communication with the resident and direct care staff on all shifts.

Nursing homes are left to determine (1) who should participate in the assessment process (2) how the assessment process is completed

(3) how the assessment information is documented while remaining in compliance with the requirements of the Federal regulations and the instructions contained within this manual.

Given the requirements of participation of appropriate health professionals and direct care staff, completion of the RAI is best accomplished by an interdisciplinary team (IDT) that includes nursing home staff with varied clinical backgrounds, including nursing staff and the resident’s physician.

The above regulation does not mention anything about anyone being MDS certified. Nowhere in the regulation does it state "MDS certified registered nurse" nor does it specify "interdisciplinary team who completed MDS certification".

In order to start doing MDS assessments, one has to know the instructions on how to answer the 50-page plus assessment form. The instructions are based on regulations. The instructions are in a >1,000 page manual [Resident Assessment Instrument (RAI) manual] released by CMS, a government entity.

If you are competent and understand the instructions and if your job description fits your facility, State and Federal regulations, then you can be part of the team that completes the MDS. Ever since MDS assessments needed completion, other IDT members involved such as Activity Directors and Social Services Designee, code the MDS or provide MDS answers and almost 100% these IDT members are not MDS certified!

So, why do you see MDS certified "a must" in job openings? Because the listing is looking for an experienced MDS coordinator or MDS staff.

How about Certificate of Completion?

Because the 2017 State Operations Manual updates included staff competency, a proof of competency such as a formal training within the past two years is being asked by the State Surveyors. The Certificate of Completion supports this staff competency requirement. The continuing education contact hours included in the certificate are directly from the California Board of Nursing and California Board of Vocational Nursing and Psychiatric Technicians. MDS/RAI Advisor's MDS 3.0 Training and other MDS-related courses' Certificate of Completion has been accepted by DHS during surveys as one of the options to be used as proof of competence for all MDS-involved IDT members.

Get the Certificate of Completion to get started!

Explore our website,, and find free information that you would otherwise need to pay for!


Cambridge Dictionary: University of Virginia: https://

Centers for Medicare & Medicaid Services Long-Term Care Facility Resident Assessment Instrument 3.0 User’s Manual version 1.17


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