CMS SNF/LTC Open Door Forum Excerpt: COT OMRA & RAI Manual Update

During the August 5, 2014 SNF/Long term Care Open Door Forum (ODF), the Centers for Medicare and Medicaid Services’ (CMS) officials addressed the Change of Therapy Other Medicare Required Assessment (COT OMRA) change associated with the FY 2015 SNF PPS Final Rule. During the ODF officials stressed that this change allows providers to use the COT OMRA “to reclassify a resident into a therapy RUG from a non-therapy RUG, but only in certain limited circumstances”. “More specifically, a COT OMRA may be completed when a resident is not currently classified into a RUG-IV therapy group but only if both of the following conditions are met: first, that the resident has been classified into a RUG-IV therapy group on a prior assessment during the resident’s current Medicare Part A stay, and second, that no discontinuation of therapy services, planned or unplanned, occurred between day 1 of the COT observation period for the COT OMRA that classified the resident into his or her current non-therapy RUG-IV group and the ARD [assessment reference date] of the COT OMRA that reclassified the resident into a RUG-IV therapy group.”

CMS officials noted that a required condition in this policy is there can be no discontinuation of therapy services, planned or unplanned, that occurred between day 1 of the COT observation period for the COT OMRA that classify the person into the non-therapy RUG and the ARD of the COT OMRA that reclassified the resident into a therapy RUG.   

COT OMRAs that are completed under this new policy should be treated like any other unscheduled assessment. According to officials, “All of the rules that would apply to that unscheduled assessment, whether they be rules of combination, rules associated with early and late penalties, etc., all of those should be considered to apply.” In addition, this revision “does not have any impact on the other OMRAs within the SNF PPS. The rules and policies associated with all other assessment types remain the same,” based on the final rule.

The FY 2015 final rule goes into effect October 1, 2014. CMS will issue a transition memo to explain how the COT OMRA change will be implemented. CMS advised this memo will be posted soon on the SNF PPS Spotlight page.