In the outpatient therapy world as well as the SNF therapy world, we have been used to change!  We don’t wonder when there will be changes, we wonder what the changes will be!  We are not in the land of Oz….we are in the land of CMS!!

Rather than encountering lions, and tigers, and bears…”OH MY!” we will have to encounter reporting therapy co-treatment minutes and distinct calendar days.   Many of us are in our groove with the MDS 3.0 but now the “wizard” (CMS) is changing to how we report Section O information on the MDS beginning October 1, 2013 (FY 2014).

Why so will we have to report the number of co-treatment minutes in the look-back period?  Because CMS would like to see how often co-treatments are taking place.

Now, are you wondering what section O is going to look like?

• Section O0400 3A is where you will enter the number of co-treatment minutes
• Section O0420 is where you will enter the distinct calendar days

Well, just click your heels three times and say, “Please show me section O“!

Counting distinct calendar days might have some wanting to go over the rainbow.  But it really isn’t that bad.  In the example below, you will see that prior to 10/1/13, the RUG is a RM (5 days of therapy) but on or after 10/1/13, the RUG is RL (4 distinct days of therapy).

	Day 1	Day 2	Day 3	Day 4	Day 5	Day 6	Day 7
PT minutes	30		30
OT minutes	30			30
ST minutes						30

The reason for reporting distinct therapy days is to ensure the accuracy in the case-mix assignment and payment.  Currently, the number of days for each therapy discipline is summed rather than counting the separate days per week that the patient receives therapy.  This results in some residents qualifying in a RM or a RL inappropriately.

I recommend discussing with your MDS Coordinator and therapy manager these changes to ensure everyone is aware and systems are in place internally within your facility to report the necessary minutes and calendar days from the therapy department to the MDS Coordinator.

We will adapt and overcome and succeed with these changes.  And there will be a happy ending!

Gina Tomcsik

Director of Compliance

Functional Pathways

[email protected]