Important Clarification Concerning the COT OMRA on the MDS

A very important clarification has been released concerning the COT OMRA on the MDS. The new clarification states that: a COT is “required when the resident was receiving a sufficient level of rehabilitation therapy to qualify for a RU, RV, RH, RM, or RL category, and when the intensity of therapy (as indicated by the total reimbursable therapy minutes delivered, and other therapy qualifiers such a s number of therapy days and disciplines providing therapy) 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.”

How does this change what we are doing now??

  • Once the COT schedule is broken and a COT is done to change the level of therapy to Nursing or a lower RUG, you cannot COT back into a higher RUG category until the next schedule assessment. In order for a COT process to continue, the patient has to qualify for a REHAB RUG on the MDS preceding the COT check.
    • You can COT to decrease the Rehab RUG or change to a nursing RUG at any time.
    • You CANNOT COT to increase that rehab RUG from a Nursing RUG if you continue to treat, until the next scheduled PPS assessment. THIS IS DIFFERENT THAN WHAT WE HAVE DONE IN THE PAST.
  • If a COT is going to change the RUG from Rehab to Nursing and Rehab continues and is medically necessary and under doctor order- the only way to get back into a Rehab RUG category, outside a normal PPS Assessment window, is to discontinue the patient from Therapy and do a SOT OMRA.
  • Communication becomes essential since missed Therapy minutes or visits could result in provider liability. It becomes important to discuss this with your rehab provider based on the PPS terms in your contract.