The fiscal year 2015 SNF PPS Final Rule includes revision to the COT OMRA completion requirements.  With the change, CMS will permit providers to use the COT OMRA to reclassify a resident into a therapy RUG from a non-therapy RUG 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 if both of the following conditions are met:

1. 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
2. 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 of the COT OMRA that reclassified the resident into a RUG-IV therapy group

The requirement does not make reference to whether the resident is in his or her first, second, third or any subsequent COT observation period because the most relevant aspect is that there can be no discontinuation of therapy services.  So as long as therapy services do not discontinue between these two points, then it does not matter which COT observation period is in play.

Discontinuation of therapy under the revised COT OMRA refers to the planned or unplanned discontinuation of all rehabilitation therapies for 3 or more consecutive days.    In addition, COT OMRAs that are completed under this new policy should be treated like any other unscheduled assessment.  All of the rules that would apply to that unscheduled assessment such as rules of combination, rules associated with late and early penalties, etc. should be considered to apply.  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.

CMS released a transition memo in August detailing that this policy will be effective for any COT OMRA that would be used to reclassify the resident into a RUG-IV therapy group from a RUG-IV non-therapy group pursuant to the rules associated with this policy if the ARD is set for on or after October 1, 2014.