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.
Topics: OMRA, Change of Therapy, End of Therapy
What is trending this week? A bit of confusion with OMRA Assessment completion. Let’s simplify.
Defining Start of Therapy OMRA
Topics: OMRA, Change of Therapy
Stand Alone OMRAs between October 1, 2016 – November 4, 2016 must be Modified. According to a QTSO Memo, all standalone OMRA assessments that were submitted to the Assessment Submission and Processing (ASAP) system beginning October 1, 2016, through November 4, 2016 need to be modified.
An issue has been identified with MDS 3.0 assessment records that were submitted to the ASAP. All Nursing Home and Swing Bed providers that submitted NO and SO assessment records with target date on or after October 1, 2106 will need to be modified. These are the item sets for the End of Therapy (EOT) and Change of Therapy (COT) when they are not combined with a scheduled assessment (5 Day, 14 Day, 30 Day etc.).
Topics: OMRA, MDS Modification
Today, we are talking about the End of Therapy OMRA. There are a couple of reasons that you would need to complete the end of therapy OMRA. One reason is when therapy services are being discontinued and the patient is going to continue to be skilled under their Medicare Part A benefit for nursing. Another reason is when there is a break in the provision of therapy services for three more consecutive days. Harmony Consultants discuss during site visits how to prevent an End of Therapy OMRA so that you can maintain your Medicare Part A revenue stream and not have an interruption in your care planning or treatment planning efforts. One of the strategies that we discuss is looking to the appointments that are scheduled for the patient, planning around those appointments or trying to schedule appointments maybe later in the afternoon so therapy can deliver service, especially when the patient is being transferred out of the building for particular appointments. Another instance you can look at is what are the activities for the day if you know a patient is going to be interested in attending a religious activity within the facility then maybe analyzing your hours of operation for therapy. Consider visits provided very early in the morning to patients or have therapists deliver treatments in the evening after the patient has had a full day of their therapy as well as visits and they may be more tired. This way the therapist can assess how the patient performs in the evening especially when the patient is going to be transferred home. This is a valuable assessment during a time when patients are most vulnerable for falls.
Topics: Medicare Part A, OMRA, Care Planning
The SNF PPS FY2012 Final Rule (76 FR 48486) outlined several policy changes in the SNF PPS effective for FY 2012. These changes include: a revised MDS assessment schedule, the Change of Therapy (COT) Other Medicare Required Assessment (OMRA), a resumption of therapy option for the End-of-Therapy OMRA, the allocation of group therapy time, and a revised student supervision policy. CMS has posted a transition document for implementation of these changes scheduled for October 1, 2011.
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.
Topics: Final Rule, Medicare Part A, CMS, OMRA
On April 28, 2011 CMS released the Proposed Rule for updates to the SNF PPS system for FY 2012. CMS has a 60 day comment period currently underway regarding these proposed changes. The deadline to file a comment is June 27, 2011. Harmony encourages SNF management and staff to read through the proposed changes and submit comments addressing support or appeal for negating the changes. The complete document can be accessed at the following link:
End-Of-Therapy OMRA
Last week in our Newsletter, Harmony discussed the start-of-therapy OMRA which will be instituted in the SNF setting beginning October 1, 2010. In addition to this new type of OMRA, CMS is changing the criteria for the End-of-Therapy OMRA. This change will also go into effect for FY 2011 with an initiation date of October 1, 2010.
The following excerpt from the Final Rule explains the upcoming changes to this assessment:
"The ARD for the end-of-therapy OMRA is to be set in a shorter time frame, that is, no more than 3 days following the cessation of all therapies."
CMS states:..."the changes to provide for a voluntary start-of-therapy OMRA and a required end-of-therapy OMRA will result in more accurate payments to providers."
As with the start-of-therapy OMRA CMS will allow for a shortened the end-of-therapy OMRA so that it consists only of the required demographic items and all of the payment items (unlike the MPAF, which includes all of the required demographic items, the payment items, and many other clinical items).
CMS plans to provide detailed MDS coding and billing instructions in the Internet-only Manuals and the RAI Manual.
