Ask the payment expert: How do I know if I need to complete a Change of Therapy OMRA?
Patricia Boyer, MSN, NHA, RN
A: This has been one of the most confusing rules that CMS has published. Many people are just as confused as you.
The Change of Therapy (COT) OMRA means that each therapy resident is always in a “look back” period. When an assessment is completed, either a scheduled assessment or an EOT-R assessment, it sets a new seven-day observation period.
So, as an example, if you set the Assessment Reference Date (ARD) of the 14-day assessment on Day 14, Day 15 begins a seven-day window that ends on Day 21.
On Day 21, you need to look back to days 15 to 21 to see if your resident's rehab level is the same as it was on Day 14. If it is, you don't need to do anything; it sets a new seven-day window that would then end on Day 28.
On Day 28, you review the resident's rehab level to make sure it is the same as the level you received on Day 14. If it is different, you must complete a Change of Therapy (COT) assessment. The rehab level can go down or up.
In addition, even if your RUG level case-mix optimized into a medical RUG, you still evaluate whether you need to complete the COT OMRA if the resulting RUG would case-mix optimize different than the present RUG.
Changes in frequency and number of therapies also can affect the requirements if your resident is an RU level of care. If it all sounds confusing, well, it can be.
The supposed logic behind this new assessment is that CMS does not want to pay you for one day more of a rehab level than you actually provided to your resident.
Next month: The solution.
Please send your payment-related questions to Patricia Boyer at email@example.com.