This question was answered by guest blogger Joel VanEaton, BSN, RN, RAC-CT, CPRA, reimbursement and RAI clinician for Care Centers Management Consulting, Inc., in Johnson City, TN. For more information about the author, please see our About page. Visit regularly for VanEaton’s answers to reader-submitted questions about the COT and EOT-R OMRAs!
Q: Can we combine a COT OMRA with a regularly scheduled PPS MDS if the ARD falls within the same ARD timeframe as the regularly scheduled PPS MDS?
A: According to the April 1, 2012 revised RAI User’s Manual and the last clarification document posted by CMS, the answer is yes. Here are the two primary rules that you need to consider when making this decision, taken from p. 1-2 of the recently revised clarification document:
- “As noted in the RAI User’s Manual, Section 2.8, there are certain instances when scheduled and unscheduled PPS assessments must be combined. Specifically, if the ARD for an unscheduled PPS assessment falls within the ARD window (including grace days) of a scheduled PPS assessment, and the ARD for the scheduled assessment would be set for a day after that of the unscheduled assessment, then the assessments must be combined.” And “…if a scheduled assessment ARD is set for a day that is after the ARD set for an unscheduled assessment, and the ARD for the unscheduled assessment is set for a day within the scheduled assessment ARD window, then the scheduled assessment is not used for payment purposes.”
- It should be noted that the above clarification of the combined assessment policy is not intended to replace or change the policy that if a scheduled assessment’s ARD is set for on or prior to day 7 of the COT observation period, the COT OMRA is not required. However, the facility may elect to combine the scheduled assessment and the COT OMRA as long as the ARD on day 7 of the COT observation is within the ARD window of the scheduled assessment. This represents a potential exception to the combined assessment policy, which facilities may choose to use in appropriate cases.