Today I want to talk about the Change of Therapy (COT) Other Medicare Required Assessment (OMRA). There are a couple of major points that should be kept in mind when considering whether COT OMRA needs to be completed. For one, how do we manage our therapy case load to prevent continually needing to complete an off schedule assessment for our PPS or our Medicare Part A patients? Always remember the COT OMRA is generated because there needs to be a change in the level of payment. This is due to the level of therapy intensity that is being provided. So, if you have a PPS Assessment and it generates a nursing RUG classification, a nursing RUG score is being paid for a particular PPS Assessment. If Therapy is involved, you are monitoring your COT Assessment Reference Dates, and the change in therapy intensity decreases, you do not need to complete a COT OMRA (if you are being paid at nursing RUG level). Many times it is forgotten that this is both clinically related as well as payment related.
Basically, Medicare is setting a standard that if you are being paid at a therapy RUG and your therapy intensity drops over a seven day period of time, they are not going to pay you for that same higher level score. Ultimately, they are going to want you to adjust your payment to reflect the actual lower level of payment that was provided. As well, you have the opportunity to complete a Change of Therapy OMRA when there is a change in therapy intensity that increases the level of care that therapy is providing to the patient over that seven day period of time. What is the bottom line you ask? Well, MDS and Therapy need to be communicating on a daily basis informing each other of happenings with particular patients. Collectively we must be tracking each COT review date for every patient on Medicare Part A. A lot to take in, we know! Please provide feedback and comments. We are more than willing to elaborate as well as continue discussion on this topic.