Have you started your COT trending analysis? On Aug. 8, the Centers for Medicare & Medicaid Services released the final ruling and commentary for the new implementation of the MDS changes set to take effect on Oct. 1. Of these many changes, I believe the most significant will be with the Change of Therapy OMRA.

“The purpose and intent of the COT OMRA, which is to determine whether the therapy provided during a successive seven-day window of therapy following the ARD of a scheduled or unscheduled PPS assessment (the COT observation period), corresponds to the resident’s RUG-IV classification as reflected on the most recent PPS assessment,” according to CMS.

As stated in the FY 2012 proposed rule (76 FR 26392), a COT OMRA would be completed for a patient in a therapy RUG, if a patient’s RTM has changed during the COT observation period to such a degree that the patient’s current RUG classification, based on their last PPS assessment, is no longer an accurate representation of the patient’s clinical condition (and the patient should be placed in a different RUG category).

So, what does this mean???

Well, RTM is the CMS language for “Reimbursable Therapy Minutes.” RTM will be the deciding factor in determining whether a COT OMRA (Other Medicare Required Assessment) will be required, if at all.

Most of our skilled nursing facilities are using some type of tracking tool for managing the prospective payment system minutes. Some are computerized, while others are still using paper forms. Regardless of the type, I highly recommend using these tracking tools to begin monitoring the therapy minutes during regularly scheduled MDS work (such as the 5-day, 14-day, etc.); and also during COT observation weeks.

The COT observation week must be scheduled exactly seven days following the previous MDS or observation week. For example, if the 14-day MDS has an Assessment Reference Date (ARD) on 8/15/11, the ARD for the next COT observation week is 8/22/11. If there has been no change in the RTM minutes and you maintain the same RUG category, no action is required. If there has been a change in RUG category, then a COT OMRA must be done and the reimbursement will drop or increase to the new RUG until another change occurs.

So, have you started conducting a trending analysis? Please feel free to email me at smesure@amesuredsolution.com to receive a free copy of my RTM management tool I’ve created begin this process. Why should we do this? With the new system, essentially, a therapy Medicare patient will ALWAYS be in an assessment period.

Traditionally, we don’t track our minutes during non-assessment periods, so conducting a trending analysis will allow facilities to anticipate possible increases or decreases in their rehab RUG utilization. It also will allow rehab and the MDS coordinators to begin the training required to fully implement the new process by Oct. 1.

In addition to using some form of the RTM Management Tool, I’ve recommended rehab facilities to start seriously looking at their weekend staffing. CMS decided to assume all SNFs should offer seven-day rehab options, so facilities that traditionally offered Monday through Friday services will face immense challenges with the new COT OMRAs.

CMS didn’t just cut our funding by 11.1%, they also significantly cut our opportunities to continue billing and providing our typical Rehab RUGs.