Long-Term Care Survey Alert

The following Q&A was provided courtesy of
Marilyn Mines, RN, BSN, RAC-CT, BC, senior manager of clinical services for FR&R Healthcare Consulting in Deerfield, Ill.

Question:
If a resident is scheduled for their 30 day assessment on day 27 of the Medicare stay, and the last day of observation for 7 day for a potential Change of Therapy (COT) falls on day 27, does the facility need to combine the 30 day assessment with the COT?
Answer:
A COT is only required if the rehab category/intensity changes. So first, you must determine if there is a change in the therapy regimen. Secondly, it is not required to do a COT if the 7^th day of observation is the ARD.
If Day 7 of the COT observation period falls within the ARD window of a scheduled PPS Assessment, the SNF may choose to complete the PPS Assessment alone by setting the ARD of the scheduled PPS assessment for an allowable day that is
on or prior to Day 7 of the COT observation period. This effectively resets the COT observation period to the 7 days following that scheduled PPS Assessment ARD. Alternatively, the SNF may choose to combine the COT OMRA and scheduled assessment following the instructions discussed in Section 2.10. (October 2012 updated RAI manual)
Note:
If the RUG payment will increase, it is suggested than a COT OMRA be completed.