If a patient receives only four days of skilled therapy in a week but does not miss three consecutive days, does a COT OMRA need to be done if there was no change in actual RTM delivered in the 7-day rolling period?

By: April 10th, 2012 Email This Post Print This Post

Q: I work in a small SNF where we work essentially five days per week and cover weekends/holidays on an as needed basis. If a patient receives only four days of skilled therapy in a week but does not miss three consecutive days (i.e., may have refused or been on hold for one day midweek), does a COT OMRA need to be done if there was no change in actual RTM delivered in the 7-day rolling period? In other words, the patient would still have enough minutes for a Rehab Medium category.

A: If a patient only receives four days of skilled therapy rather than the five days that are required in regulation, you would need to complete the COT assessment. Any change to the reimbursable therapy minutes, number of days of therapy, number of disciplines of therapy, or restorative nursing (rehab low categories) that impact a RUG score necessitates a COT assessment. In your scenario, even though the patient is still receiving therapy, the RUG score would change to a nursing category, because you need five days of therapy to remain in a rehab category.

Comments

By Elaine Silver on April 10th, 2012 at 3:36 pm

If I am not mistaken, there is one exception to the 5 day rule. If a resident is receiving OT and PT but it’s a 5-day split, they could be receiving one 3-days/wk and the other 2-days/wk and it doesn’t matter if they are both given on the same days. This is what I was taught, is it wrong???

By melissa green on April 10th, 2012 at 4:23 pm

You are correct 3 day OT and 2 of PT would still get you the RM so if the 4 day scenario above included 2 disciplines you could get RM and no COT would be needed.

I would seek further clarification of this. Our organization has experienced instances of downcoding and denial of claim by Medicare Advantage plans citing this exact reason (therapy not provided over 5 calendar days). When I contacted CMS, they supported this interpretation and we had to change our practice. In addition, an ADR recently mentioned this in the remarks section of the outcome for the claim being denied.

 

Leave a Comment

*

« | Home | »

Subscribe - Get blog updates via e-mail

hcpro.com

Login to connect with Others on MDSCentral:


Directory

Powered by Small Mingle Icon Mingle

11,401 Users - Show All