Does the COT allow us to re-RUG to a higher rehab level?

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.


  1. Anita Whipple

    Re: COT OMRA’s – if I have a 14 day PPS assessment with a 9/30/11 ARD, do I review for a possible COT OMRA on 10/7, or wait until after the 30 day PPS assessment with an ARD of 10/16 (review of 10/17-10/23/11)?

  2. Mike Sullivan

    Here is a scenario for which I hope you have a solution on the connection of COT MDS to Billing:

    5 day MDS running.
    COT effective on day 13.
    Does this COT cover days 13 & 14 only for billing the Medicare A claim?

    Thanks in advance.

  3. melissa green

    we can no longer inactivate an MDS and recode it with a different reason code with the same ARD. My question is what happens when a 14 day was combined with a COT and submitted. It was later determined that the minutes for the 14 day MDS were inaccurately entered and a COT was not needed? I can modify the original MDS (14/COT) minutes but it is not coded correctly since a COT did not occur

  4. sue

    i have a patient that a 30 day pps assessment was completed,locked and transmitted.We picked day 29 for this assessment,which also was a cot lookback day as rug was going down we did not combine.
    This patient was sent out and admitted to the hosp on day 31,do I now need to inactivate the 30 and do a cot for day 29

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