CMS has mandated the initiation of the new type of OMRA, a Change of Therapy, which may just be the most discussed element in the Final Rule to date. Details of this OMRA are discussed on pages 196 - 217 of the Final Rule. Effective October 1st, 2011, for all Medicare Part A SNF residents, a COT OMRA is required if the therapy services a resident receives during the COT observation period do not reflect the RUG-IV classification level given on the patient's most recent PPS assessment used for payment and would instead cause the patient to be classified into a different RUG category. The term "COT observation period" refers to a successive 7-day window beginning the day following the Assessment Reference Date (ARD) of the resident's last PPS assessment used for payment.
Evaluation of the necessity for COT OMRA must be completed every seven calendar days starting from the day following the ARD set for the most recent scheduled or unscheduled PPS assessment.
- This rule applies whether the change in therapy delivery is scheduled/planned or unscheduled/unplanned and whether the RUG category is higher or lower.
- COT is required if:
- A therapy discipline is discontinued resulting in a lower number of therapy disciplines to meet the paying RUG.
- If a patient fails to receive the requisite number of minutes or days of therapy required for classification into the paying RUG.
COT OMRA has a "rolling" 7 day observation window.
- Beginning on the day following the ARD set for the most recent scheduled or unscheduled PPS assessment OR
- The day therapy resumes in cases where and EOT-R OMRA is completed.
- The COT OMRA ARD would be set for day 7 of a COT observation window.
- Rolling 7 day observation window ends every 7 calendar days thereafter.
- The HIPPS code derived from the COT OMRA would be effective (on the UB-04) starting the first day of the COT OMRA observation window/period.
- This new RUG score/HIPPS code would remain in effect until the end of the payment window or until a new unscheduled PPS assessment is completed (including another COT OMRA if warranted).
- COT OMRA can be combined with regularly scheduled PPS assessments. (Examples of this are provided in the Final Rule).
The COT OMRA will be applicable for all assessments with an ARD on or after October 1, 2011.
CMS has posted a transition document for implementation of changes scheduled for October 1, 2011. To access this document see the link below: