The New COT OMRA: How Will Your Facility Manage?

This article was written by Harmony Healthcare in the October 5th Newsletter Issue:

Effective October 1st, a COT OMRA will be required for patients classified into a RUG-IV therapy category whenever the intensity of therapy changes to such a degree it no longer reflects the RUG-IV classification and payment assigned based on the most recent assessment used for Medicare payment.  CMS stresses that SNFs would be required to complete a COT OMRA only if the intensity of therapy changes to such an extent that the patient’s RUG classification, based on their last PPS assessment, is no longer an accurate representation of the patient’s current clinical condition.  This change in the therapy intensity may be due to scheduled changes or unscheduled changes.  The COT is indicated when the different RUG category is higher or lower than the RUG category in which the resident is currently placed.

If a therapy discipline is discontinued and this results in a patient no longer meeting the required number of therapy disciplines for the patient’s current RUG category then a COT OMRA would be required. In addition, if a patient fails to receive the requisite number of days of therapy required for classification into the RUG category, then a COT OMRA would be required to change the patient’s RUG category as appropriate.

The ARD for the COT OMRA would be set for day 7 of a COT observation period.  Beginning on the day following the ARD set for the most recent scheduled or unscheduled PPS assessment (or the day therapy resumes in cases where an EOT-R OMRA is completed) there will be a rolling 7-day look-back.  For example, if the facility uses PPS day 13 as the ARD for the 14 day assessment, the end of the rolling 7-day look-back period will be PPS day 20.  If on PPS day 20 the minutes are no longer an accurate representation of the previous RUG score, a COT OMRA will be required.

Payment begins the day after the ARD, the beginning of the COT look back period and remains in effect until the end of the payment window for the previous assessment or until a new unscheduled assessment (an OMRA, SCSA, or SCPA) is completed.


The 14 day PPS assessment ARD was 10/8 day 13, with a RUG category of RU (720 minutes) representing the payment category. The start of the COT observation period begins the day after the ARD of the 14 day PPS assessment (COT day 1= PPS day 14, 10/9/11) and continues to COT day 7 (10/15/11), which is PPS day 20.

The patient may achieve the represented RUG at any time during the look back period (think of it as the same look back period when completing a PPS assessment).  However, the minutes and days may only be looked back upon during that seven day COT look back period.  If a COT is not completed, the next COT observation period will begin the day following day 7 of the previous COT period.  Harmony stresses that it is imperative to monitor the therapy disciplines, days and minutes that are captured within each 7 day look back period for determining if a COT is required.

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