Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
The Change of Therapy (COT) OMRA and End of Therapy (EOT) OMRA Assessment completion can be complex and confusing.
It is not uncommon to observe an unnecessary End of Therapy (EOT) Assessment completed resulting in payments at a Nursing RUG Level versus a Rehabilitation RUG Level.
Sometimes, a Change of Therapy (COT) Assessment may be combined with scheduled MDS Assessments even when this is not required per RAI Guidelines. This may result in an adjusted or reduced RUG Payment Level for 7 Days, even though the assessment was not indicated.
It must also be noted that CMS requires that all COTs and EOTs are scheduled on a computerized or paper MDS within 2 days. There is the potential to bill the default rate or even enter a provider liable situation (if the assessment is not scheduled within 2 days of the end of their Medicare stay).
To prevent the above scenarios, the Harmony HealthCARE Specialist provided the team with the proper requirements that govern EOT and COT completion. These clarifications are critical for accurate and appropriate reimbursement.
Change of Therapy (COT) OMRA
CMS intentionally clarified that if the ARD of a scheduled assessment is the 7th day of the COT observation period. The assessments do not need to be combined, however, facilities do have the option to combine the assessments if they choose.
For Example: If the 5-Day MDS has an ARD of 12/21 (Day 8) a COT review is required on 12/28 (Day 15) and the 14-Day PPS Assessment is scheduled with an ARD of day 13, 14 or 15, there is no requirement to combine the COT and the scheduled assessment.
If day 15 is chosen, however, you may combine them. Facilities should closely review ARD selection of the standard scheduled assessments. If the COT review is completed on the ARD, facilities must review whether it is financially beneficial to combine the assessment with a COT Assessment.
Some other helpful Change of Therapy (COT) OMRA tips include:
- If the ARD of a standard assessment is the same as the required COT review date for the previous assessment, combining the assessment with a COT is optional. Note that this only applies when the scheduled assessment is used for payment.
- If the patient discharges from the facility on the required COT review, completing a COT is optional.
For Example: The patient is an RV Level on their 30-Day Assessment with an ARD of day 30. On day 37 the patient is a RH Level. The patient discharges from the facility day 37. A COT is not required.
Conversely, if the RUG Level increases to an RU Level, a COT may be completed. A COT may be combined with a discharge assessment.
- If the patient’s last covered day is on a required COT review date and the RUG level changes, a COT is required.
For Example: The patient is an RV Level on their 30-Day Assessment with an ARD of day 30. On day 37 the patient is a RH Level. The patient’s last covered day is day 37 and the patient remains in the facility. A COT is required.
End of Therapy (EOT) OMRA
The key to determining whether an EOT OMRA is required is no longer solely related to whether skilled therapy has been discontinued. If the facility will be paid for the 3rd day of missed therapy, then an EOT must be completed.
End of Therapy (EOT)) requirement tips:
- If the patient discharges from the facility on or before the 3rd day of missed therapy an EOT is not required.
For Example: Therapy is received on Monday. No therapy is provided on Tuesday, Wednesday and Thursday. The patient discharges from the facility on Thursday. An EOT is not required.
- If the patient’s last covered day is before 3 days of missed therapy. For example, therapy is received on Monday. No therapy is provided on Tuesday, Wednesday and Thursday. The patient last covered day is Thursday. A EOT is If the patient’s last covered day is Wednesday, an EOT is not required.
- If the RUG Level currently paying is a Nursing RUG Level (e.g. due to index maximizing) and therapy discontinues, an EOT is not required.
- The COT Process of review continues until the ARD of an EOT, therefore, if the facility chooses not to complete an EOT, COTs must be monitored and completed as needed.
Facilities are reminded that for completion of the Change of Therapy (COT) OMRA and the End of Therapy (EOT) OMRA:
The decision for which day within the allowable ARD window that the ARD of the assessment may be set, may be after the window has passed.
For Example: If a resident misses therapy on July 2, 3 and 4, the facility must complete an EOT OMRA for this resident and the ARD must be set for either July 2nd, 3rd, or 4th. However, the decision for which of those days should be used for the ARD on the EOT OMRA may be made after July 4th and within two days of the last day of the ARD window.
The assessment must be completed within 14 days from the ARD.
Daily Meetings between the MDS and Rehabilitation department are integral for success. Ongoing dialogue on all aspects of OMRA include:
- ARD Selection and
- Determination whether to combine or not combine assessments.
Harmony Healthcare International (HHI) reiterates the need to closely monitor and reference the above COT and EOT Rules. Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have. You can contact us by clicking here. Looking to train your staff? Join us in person at one of our our upcoming Competency/Certification Courses. Click here to see the dates and locations.
6th Annual LTPAC Symposium
Click Here to Register