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: It is not required to do a COT if the 7th day of the observation period is the ARD date, says Marilyn Mines, RN, BC, RAC-CT, senior manager of clinical services for FR&R Healthcare Consulting, Inc. in Deerfield, IL. However, if the intensity of therapy as indicated on the 7th day would result in a higher RUG Rehab category, it is beneficial to combine the 30 day assessment with a COT to increase revenue.
Chapter 2-51 of the RAI Manual says, if the assessment date is set prior to the end of the 7 day observation for a possible COT, the scheduled PPS assessment may be done alone, and will reset the COT observation period. Alternatively, the SNF may choose to combine the COT OMRA and scheduled assessment following the instructions discussed in Section 2.10.
Note: If the RUG payment will increase, it is suggested that a COT OMRA is completed.