Thursday, August 14, 2014

CMS SNF/LTC Open Door Forum Excerpt: COT OMRA & RAI Manual Update

Holly Harmon

During the August 5, 2014 SNF/Long-term Care Open Door Forum, CMS officials addressed the Change of Therapy Other Medicare Required Assessment (COT OMRA) change associated with the FY 2015 SNF PPS Final Rule.

This changes allows providers to use the COT OMRA “to reclassify a resident into a therapy RUG from a non-therapy RUG, but only in certain limited circumstances,” stressed officials during the ODF. “More specifically, a COT OMRA may be completed when a resident is not currently classified into a RUG-IV therapy group but only if both of the following conditions are met: First, that the resident has been classified into a RUG-IV therapy group on a prior assessment during the resident’s current Medicare Part A stay, and second, that no discontinuation of therapy services, planned or unplanned, occurred between day 1 of the COT observation period for the COT OMRA that classified the resident into his or her current non-therapy RUG-IV group and the ARD [assessment reference date] of the COT OMRA that reclassified the resident into a RUG-IV therapy group.”

CMS officials noted that a required condition in this policy is there can be no discontinuation of therapy services, planned or unplanned, that occurred between day 1 of the COT observation period for the COT OMRA that classify the person into the non-therapy RUG and the ARD of the COT OMRA that reclassified the resident into a therapy RUG.  

COT OMRAs that are completed under this new policy should be treated like any other unscheduled assessment, said officials. “All of the rules that would apply to that unscheduled assessment, whether they be rules of combination, rules associated with early and late penalties, etc., all of those should be considered to apply.” In addition, this revision “does not have any impact on the other OMRAs within the SNF PPS. The rules and policies associated with all other assessment types remain the same,” according to the final rule.

The FY 2015 final rule goes into effect October 1, 2014. CMS will issue a transition memo to explain how the COT OMRA change will be implemented. CMS advised this memo will be posted soon on the SNF PPS Spotlight page.


RAI Manual update

CMS officials announced the next update to the RAI User’s Manual for the MDS 3.0 “is on track” for release “on or about” September 5, 2014. The revision will be posted at the agency’s official RAI Manual page. Providers should expect to see more details about the revised COT OMRA policy in this manual update. 

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