Harmony Healthcare International (HHI) Blog

COT Assessment through the Eyes of CMS

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Change of Therapy Assessment as it was discussed during the CMS Provider training in St. Louis, MO.: 

CMS officials discussed that when you are looking at your COT assessment dates and the potential ARD for when a COT would need to be completed, you have to take into consideration that the COT must be completed if an assessment (that is a standard assessment) that is used for billing is not utilized.

For example, they talked about a 30 day assessment; if the Assessment Reference date for a 30 day assessment was set for day 27 and ,if subsequently, this was also a COT review date. Even though the therapy intensity decreased, the COT was not completed because day 27 was utilized for a scheduled PPS assessment.  Well if that patient is to leave the building and the scheduled 30 day assessment is never utilized for actual billing then the facility is responsible to have completed the COT on that day 27.  This is a very sticky situation and providers were questioning CMS on how do we solve this problem and how are we going to work around this because sometimes you don’t foresee if a patient is going to leave.  CMS is standing by this rule at this time. Harmony would love to hear from anybody who wants to contribute to suggestions as we will be submitting our suggestions to CMS.   At this present time CMS has it set that if for example, a 30 day assessment is completed but is never used for billing and a COT was required but not completed, the provider could be at risk for potential default days or a decrease in revenue for services that were actually provided to the patient. 

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Topics: CMS, ARD, Change of Therapy


Kris Mastrangelo, OTR/L, LNHA, MBA

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Kris Mastrangelo, OTR/L, LNHA, MBA
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