HIPAA-Compliant AI for Skilled Nursing Facilities: The Complete Operator's Guide

Section GG is the MDS 3.0 section recording functional abilities and goals, covering self-care and mobility. Items are scored on a six-level scale from dependent to independent based on usual performance during the assessment window. Section GG drives the function score used in PDPM payment classification and feeds SNF Quality Reporting Program measures.

Section GG does two jobs at once, which is why it gets so much attention. It determines a component of Medicare payment, and it produces publicly reported quality measures. A coding practice that shades one direction affects both.

Key takeaways

  • Section GG covers self-care and mobility items scored 06 down to 01, plus activity-not-attempted codes.
  • The standard is usual performance across the assessment window, not the resident's best single effort.
  • Admission performance is coded from the first three days of the Part A stay; discharge performance from the last three.
  • The function score derived from Section GG feeds the PT, OT, and nursing components of PDPM.
  • Coding from a single therapy observation is the most common and most consequential error.

What Section GG covers

Two groups of items:

  • Self-care — eating, oral hygiene, toileting hygiene, and various levels of upper and lower body dressing, bathing, and personal care
  • Mobility — bed mobility including rolling and sit-to-lying transitions, transfers including chair and toilet transfers, walking at defined distances, and wheelchair mobility where applicable

The scoring scale

CodeLevelMeaning
06IndependentCompletes the activity with no assistance
05Setup or clean-up assistanceHelper sets up or cleans up; resident completes the activity
04Supervision or touching assistanceVerbal cues or steadying contact
03Partial or moderate assistanceHelper does less than half the effort
02Substantial or maximal assistanceHelper does more than half the effort
01DependentHelper does all the effort, or two or more helpers required

Where the activity did not occur, activity-not-attempted codes record why — the resident refused, the activity was not applicable, or it was not attempted due to medical condition or safety concerns. These are not interchangeable with a low score, and using 01 when the correct entry is an ANA code misrepresents the resident.

Usual performance, not best performance

This is the rule that most coding disputes turn on. Section GG asks what the resident usually did during the assessment window, not what they were capable of on their best attempt.

A resident who transferred with substantial assistance on five occasions and with supervision once did not usually transfer with supervision. Coding the best observation inflates function, which lowers the PDPM function score contribution and simultaneously misrepresents the resident in quality reporting.

The corollary matters too: coding worse than usual performance to increase payment is equally wrong, and it is the direction medical review looks for.

Because usual performance spans a window and multiple shifts, Section GG cannot be coded accurately from therapy documentation alone. Therapy sees the resident in a structured session, often at their best. Night shift sees something different. An accurate score requires input from everyone who assisted the resident.

The assessment windows

  • Admission performance is coded from the first three days of the Medicare Part A stay, starting with the date of admission.
  • Discharge performance is coded from the last three days of the stay, ending with the discharge date.
  • Discharge goals are established at admission, representing expected function at discharge.

The three-day admission window is unforgiving. If nobody gathers interdisciplinary input in the first 72 hours, the data to code accurately no longer exists, and the score becomes a reconstruction.

How Section GG feeds PDPM

Selected Section GG self-care and mobility items are combined into a function score that contributes to the PT, OT, and nursing case-mix components. See the PDPM guide for how the components combine into a per-diem.

Section GG items also feed SNF Quality Reporting Program measures on functional change and discharge function, which are publicly reported. Failure to report required QRP data carries a payment penalty.

The errors that cost the most

  1. Coding from a single therapy observation. Structured session performance is not usual performance.
  2. Coding best performance. The instrument asks for usual.
  3. Missing the three-day admission window. Data gathered later is reconstruction.
  4. Using 01 instead of an activity-not-attempted code. Different meanings, different implications.
  5. No interdisciplinary input. Nursing assistants provide most of the assistance and are least often asked.
  6. Discharge goals never set, which is a QRP reporting failure.

Where AI helps

Section GG accuracy is a corroboration problem: does the score match what everyone documented?

  • Read nursing, therapy, and aide documentation across the three-day window and identify where documented assistance levels conflict with the coded score.
  • Surface documentation from shifts that were not consulted before coding.
  • Flag items where the record supports an activity-not-attempted code rather than a performance score.
  • Compare admission and discharge coding against the interim record for plausibility.

Hathr.AI runs Anthropic Claude models inside AWS GovCloud under a FedRAMP High authorization boundary, signs a Business Associate Agreement within 24 hours on every plan, and reads the handwritten flowsheets where aide-documented assistance levels usually live — which is exactly the source most often missing from Section GG coding.

The boundary: AI does not score Section GG. A registered nurse certifies the assessment under 42 CFR 483.20.

Check one assessment

Upload three days of documentation for a recent admission and ask Hathr.AI whether the record supports the Section GG scores you coded.

Start a free trial — $47 a month, no seat minimum, BAA in 24 hours →

Frequently asked questions

What is Section GG on the MDS?
The MDS 3.0 section recording functional abilities and goals, covering self-care and mobility items scored on a six-level scale.

What do Section GG scores mean?
06 is independent, 05 setup assistance, 04 supervision or touching assistance, 03 partial or moderate assistance, 02 substantial or maximal assistance, and 01 dependent.

Is Section GG coded on best or usual performance?
Usual performance across the assessment window, not the resident's best single attempt.

What is the Section GG assessment window?
Admission performance is coded from the first three days of the Part A stay; discharge performance from the final three days.

How does Section GG affect PDPM?
Selected items combine into a function score contributing to the PT, OT, and nursing case-mix components.


Part of the HIPAA-Compliant AI for Skilled Nursing Facilities hub. Related: What Is PDPM? · Using the CMS RAI Manual

General regulatory information, not clinical or coding advice. Verify item definitions and windows against the current CMS RAI Manual.

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Written by
Sam Hart headshot - Founder at Hathr.ai
Hathr.AI Clinical Compliance Team
Date Published:
2026-08-15

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