Shelly Mesure, MS, OTR/L

On Oct. 1, the Centers for Medicare & Medicaid Services will be updating the Minimum Data Set with another round of changes. Most are minor but there will be two changes to the therapy section. Your case-mix utilization and scheduling, will determine the degree of impact of these new changes.

The therapy changes:

1.   Section O0400 (A3A, B3A, and C3A) — This is Speech, Occupational, and Physical therapy sections. The new question to report is: “3A. Co-treatment minutes — record the total number of minutes this therapy was administered to the resident in co-treatment sessions in the last 7 days.”

2.   Section O0420 — The new question to report is: “Record the number of calendar days that the resident received Speech-Language Pathology and Audiology Services, Occupational Therapy, or Physical Therapy for at least 15 minutes in the past 7 days.”

So, let’s start with question No. 1 — Co-treatment minutes. At this time, physical, occupational and speech therapy may count the full treatment minutes of their co-treatment session as long as their treatment relates back to the patient’s discipline-specific plan of care. When we operated under the MDS 2.0 version, we used to receive credit only for a portion of the minutes as they would be divided by how many disciplines treated during the same timeframe. Although we will now have to report the full co-treatment minutes on the MDS, we will continue to receive the full credit of the minutes per the current regulations.

Previously, it was recommended to include in your documentation whenever co-treatment sessions were conducted. This is still my recommendation. However, the reporting must also be reflected on the billing grids. If you are using a computerized system, the updates should be appearing very soon; if you still have paper records, I would add another row to your logs for recording just the co-treatment minutes.

I would also recommend adding audits to ensure that if co-treatment has been billed, the clinical documentation also reflects the services as it relates to each scope of practice. Duplication of services is one of the top reasons for denials with many claims.

For item No. 2, this may or may not have a significant impact with your department. To achieve the Rehab Ultra High, Very High, and High payment categories, the RUG payment system requires at least one discipline to treat a minimum of five distinct calendar days for at least 15 minutes in the past seven days.

Therefore, I would recommend a quick analysis of how many rehab Medium and Lows are typically on the therapy schedule. Next, I would look at these patients, and figure out how many disciplines are treating, and at what frequency.

For example, if a patient is scheduled for the rehab medium with one discipline, 30 minutes/treatment, five times per week, then no changes need to be made. However, if a patient is scheduled for the rehab medium with two disciplines, 30 minutes/treatment, three times per week, then the schedule should be planned to cover five distinct calendar days (PT – Monday, Wednesday, Friday; OT – Tuesday, Thursday, Saturday) as a possible scenario.

Since this is an MDS change, it affects all payments determined by the RUG system, and may include Medicaid payments if you work in a case-mix based State.

So, luckily, there’s nothing to panic about. However, don’t fall behind if your facility isn’t brought up-to-date.


Shelly Mesure (“Measure”), MS, OTR/L, is the senior vice president of Orchestrall Rehab Solutions and owner of A Mesured Solution Inc., a rehabilitation management consultancy with clients nationwide. A former corporate and program director for major long-term care providers, she is a veteran speaker and writer on therapy and reimbursement issues.