CMS Clarification Memo: Combined COT OMRA & Scheduled ARD's
A VP of Therapy Operations in Arkansas writes …..
“I reviewed the recent SNF PPS Clarifications Memo V1.1, dated March 2012 and would like to know how to best manage this issue. My greatest concern is selecting the correct ARD and thus preventing a lower “default” per diem reimbursement for Medicare Part A patients.”
CMS writes in the March 2012 Clarification Memo …..
“A COT OMRA has an ARD of day 13 and a 14-day assessment is completed separately with an ARD of Day 15. The COT OMRA in this case would begin paying on day 7 (day 1 of the COT observation period), pay through day 15, and continue until the next scheduled or unscheduled PPS assessment used for payment. Additionally, the next COT evaluation date is day 20, since that is 7 days after the ARD of the COT OMRA. The completion of the 14-day assessment with an ARD of day 15 in this example means that the ARD was set improperly and the 14-day assessment would not be used for payment.”
“If a COT OMRA has an ARD set for day 13 and the facility sets the ARD of the 14-day assessment for Day 13, then the facility may choose either to complete only the 14-day assessment or to combine the 14-day assessment and COT OMRA. However, if the ARD of the 14-day assessment were to be set for day 14, then this would violate the combined assessment policy. In such a scenario, the COT OMRA would still be required with an ARD of day 13, and the 14-day assessment would not be used for payment.”
Strategies to Prevent Default Reimbursements for Medicare Part A
If the COT OMRA day pre-dates the scheduled ARD, then the COT OMRA day takes precedence. "Preventing" ARD’s that result in default per diem reimbursements is the only effective strategy to maintain Medicare Part A revenue. You cannot go back and change the ARD once selected. You do have greater flexibility in selecting alternative ARD's if the COT OMRA day post-dates the scheduled ARD. Our management tools are designed to take advantage of this flexibility. CarePoint therapy management software prevents instances where the COT OMRA day pre-dates the scheduled ARD as follows:
§ Pre-select day 8 as the 5-day assessment when possible. Then, the 14-day assessment can be days 13, 14, or 15 allowing time to react to a shortfall in minutes or days. CarePoint indicates the minutes and days required to achieve the targeted RUG's level by day 8.
§ Our COT OMRA Management Report shows the progress toward maintaining that RUG's level during the 7-day COT OMRA observation period. If either days 12, 13, or 14 are the "fixed" COT OMRA day, then we suggest you "front load" treatments across the first 5 days to make sure you don't miss the targeted RUG's level.
§ The COT OMRA Management Report is linked to our Scheduling tool to ensure that proper minutes and days are planned well in advance of the COT OMRA day.
Prevention is the only way to go to protect yourself from combined assessments that go against you and result in default per diem reimbursements. CarePoint has all the tools necessary to prevent instances where the COT OMRA day pre-dates the scheduled ARD and thus minimizes the risk of lost revenue.