Q: Does the COT allow us to re-RUG to a higher rehab level? Also, does the new RUG category take effect the day after the COT ARD?
A: If a resident starts receiving enough therapy to classify into a RUG-IV category that is higher than his or her current category, then yes, completing a COT would allow you to re-RUG at the higher, more appropriate RUG level. The ARD for the COT OMRA would be set for day 7 of the observation period, which is a rolling seven-day window beginning on the day following the ARD set for the most recent scheduled or unscheduled PPS assessment and ending every seven calendar days thereafter. The new RUG-IV group resulting from the COT OMRA would be billed starting the first day of the COT observation period and would remain at this level until a new assessment is completed, which changes the resident’s RUG-IV classification.
Let’s look at an example. If a SNF sets the ARD for its 14-day assessment to day 14, then day 1 for the purposes of the COT observation period would be day 15 of the SNF stay, and the facility would be required to review its therapy minutes for that resident for the week consisting of days 15-21. If the SNF determines that the total therapy minutes received has changed such that the RUG classification from the 14-day assessment is no longer accurate, then the SNF would complete a COT OMRA with an ARD of day 21. Payment at the RUG rate determined by the COT OMRA would begin on the first day of the COT observation period, which was day 15.