Harmony Healthcare Blog

CMS Clarifications on COT OMRA questions and more!!!

Posted by The Harmony Team on Wed, Oct 05, 2011

Edited by Kris Mastrangelo

CMS, RAI Manual, PPSCMS is  diligently working on tying up any loose ends to prepare the long term care industry for the October 1st changes that are only 4 days away.  CMS has posted a clarification document in regards to the recent comments and question and answer session on the Provider Training Calls conducted August 23 and September 1.  

Harmony has provided a few of the significant clarifications below.    


Q: Clarification regarding what should be considered as part of the "intensity of therapy" provided to a resident.  

A: "Intensity of therapy" includes all qualifiers for a given therapy category, such as the RTM, days of therapy, therapy disciplines, and restorative nursing programs in the case of Rehabilitation Low.


Q: Clarification regarding the number of minutes outside the current RUG category a patient's therapy must be to require a COT OMRA.   

A: Any amount of minutes which would constitute a change in the therapy category could necessitate a COT OMRA. For example, if a patient classified into Ultra High Rehabilitation receives 719 minutes of therapy during the COT observation period, then this would constitute a change in the resident's therapy RUG category.   


Q: Clarification regarding the existence of a "Medicare week".
A: The 7 day lookback period used for a COT observation period is determined based on the ARD of the patient's other assessments, not on a standardized weekly schedule.    


Q: Clarification regarding whether Leave of Absence days count as in the 7 day COT observation period

A: Pending


Q: Clarification regarding completion of interview questions for a COT OMRA. 

A: In relation to the interview questions on the COT OMRA, facilities may complete the resident interviews within a day or two of the ARD of the COT OMRA. If the interviews are not completed by this time, then facilities should use the staff assessment to complete that portion of the COT OMRA. We would note, however, that given the types of changes in the intensity of therapy that would prompt the need for a COT OMRA, facilities are expected to continually evaluate the therapy intensity for a given SNF resident and anticipate the possibility that a COT OMRA may be necessary.

Q: Clarification regarding when the group therapy policy will be effective.

A: On any assessments with an ARD on or after October 1, 2011, group therapy minutes will be allocated regardless of whether the look back period extends prior to October 1, 2011 However, to allow for a smooth transition for billing between FY 2011 and FY 2012, facilities will be given the appropriate FY 2012 RUG code on the final validation reports associated with assessments submitted after September 18th, 2011 with an ARD between August 22nd, 2011 and September 30th, 2011 in error message number 1059. For assessments with an ARD on or after October 1, 2011, the FY 2012 RUG-IV code listed in item Z0100 of the assessment will be validated and the appropriate FY 2011 RUG group will be provided on the final validation reports associated with these assessments in error message number 1060. Facilities should bill the appropriate FY 2012 RUG, which will have all group therapy minutes allocated, beginning on October 1, 2011.


Q: Clarification regarding the minimum number of therapy minutes which constitute a therapy day.

A: If a patient receives 15 or more codable minutes of therapy in one discipline in a given day , including a therapy evaluation, then this would count as a therapy day.


The complete Clarification document can be found at the link below:  




RAI Manual updates can be found at the following page:



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