CMS proposes the Change of Therapy OMRA

The long-term care industry has wide eyes and an ear to the ground following the initial publishing of the Centers for Medicare & Medicaid Services Proposed Rule for SNF PPS FY 2012 (PDF format). Many aspects of the Resident Assessment Instrument process are discussed and some major adjustments to how the SNF team manages each patient are presented.

One of the newly proposed items to implement will be a Change of Therapy other Medicare required assessment (COT OMRA). This new assessment is defined by CMS as being required when “a patient’s RTM [reimbursable therapy minutes] changes to the extent that the patient’s RUG classification, based on their last PPS assessment, is no longer an accurate representation of their current clinical condition.” (For the sake of definition: ‘‘‘[R]eimbursable therapy minutes’ are those minutes used to classify a patient for therapy purposes. For each of the RUG-IV categories, it is the number of reimbursable therapy minutes that is used to classify a given patient into a therapy RUG-IV group.”)

CMS believes that instituting a requirement to monitor the levels of care provided by therapy—via a rolling Assessment Reference Date, or ARD—would allow the agency to track changes in the patient’s condition and in the provision of therapy services more accurately. The desired result is improved accuracy of reimbursement for therapy services, which theoretically enhances the SNF’s ability to provide quality care to SNF residents.

The daily management and oversight of minutes is an intensive process. This is something that should currently be in place within the rehab department. Software capabilities with the onset of MDS 3.0 have improved and expanded significantly. A quick view of daily minutes provided to all patients yields valuable information for managing caseloads, streamlines department efficiency and facilitates communication with the interdisciplinary team.

The following excerpt is taken directly from the CMS Proposed Rule:

[W]e have found some cases where therapy services recorded on a given PPS assessment did not provide an accurate account of the therapy provided to a given resident outside the observation window used for the most recent assessment. We believe that when service levels change, whether inside or outside the observation period, such changes should be based on medical evidence […]We propose that, effective for services provided on or after October 1, 2011, SNFs would be required to complete a Change of Therapy (COT) OMRA, for patients classified into a RUG-IV therapy group, whenever the intensity of therapy (that is, the total RTM delivered) 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. The COT OMRA would be a new type of required PPS assessment, which would use the same item set as the current EOT OMRA. The ARD for the COT OMRA would be set for Day 7 of a COT observation period, which is a rolling 7-day window beginning on the day following the ARD set for the most recent scheduled or unscheduled PPS assessment (or beginning the day therapy resumes in cases where an EOT-R OMRA is completed[…]) and ending every 7 calendar days thereafter […] We want to stress that SNFs would be required to complete a COT OMRA only if a patient’s total RTM changes to such an extent that the patient’s RUG classification, based on their last PPS assessment, is no longer an accurate representation of their current clinical condition. However, an evaluation of the necessity for a COT OMRA (that is, an evaluation of the patient’s total RTM) must be completed every seven calendar days starting from the day following the ARD set for the most recent scheduled or unscheduled PPS assessment.