Ask the Payment Expert ... about Change of Therapy assessment

Patricia Boyer
Patricia Boyer

We were told that we missed a Change of Therapy assessment, but we can't be penalized for not completing a COT that would have raised our reimbursement, can we?

In a word, yes.

The RAI manual says COT is “...Required when the resident was receiving a sufficient level of rehabilitation therapy to qualify for an Ultra High, Very High, High, Medium, or Low Rehabilitation category and when the intensity of therapy (as indicated by the total reimbursable therapy minutes [RTM] delivered, and other therapy qualifiers such as number of therapy days and disciplines providing therapy) changes to such a degree that it would no longer reflect the RUG-IV classification and payment assigned for a given SNF resident based on the most recent assessment used for Medicare payment.”

A COT is required when the RUG level increases or decreases. If you do not complete a COT when required, you will be considered to have a late or missed assessment. 

There can be financial ramifications. The RAI Manual notes: “If the SNF fails to set the ARD within the defined ARD window for a Medicare-required assessment, including the grace days, and the resident is still on Part A, the SNF must complete a late assessment. The ARD can be no earlier than the day the error was identified.”

This would result in no payment if the late COT were completed after an intervening payment assessment. A missed COT results in the same. 

If your resident is still on Medicare A, you can bill the default rate for the days the COT would have paid for. If your resident is no longer on Medicare A, the days would be provider liable and you will receive no payment. 

The lesson here is that COT completion is critical. You need to have a system in place that tracks potential COTs

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