Lizeth Flores, RHIT, RAC-CT Anderson Health Information Systems, Inc MDS 3.0 FY 2012 Presented by Lizeth Flores, RHIT, RAC-CT Anderson Health Information Systems, Inc office@ahis.net 714 -558 - 3887

MDS Changes for FY 2012 MDS 3.0 2012 EOT-R COT-OMRA New Schedule Group Therapy Therapy Supervision

Agenda 1. New Assessment Schedule 2. EOT & EOT-R OMRA 3. COT-OMRA 4. Allocation of Group Therapy 5. Therapy Student Supervision

NEW ASSESSMENT SCHEDULE October 1st, 2011 will mark the biggest reduction in Medicare RUG rates for our industry since the inception of the SNF PPS program, a reduction of approximately 11.1%

NEW ASSESSMENT SCHEDULE In order to avoid overlapping look-back periods a new assessment schedule will be implemented effective October 1, 2011

NEW ASSESSMENT SCHEDULE All PPS assessments with an ARD on or after 10/1/11 must use the updated MDS assessment

What Changed? NEW SCHEDULE OLD SCHEDULE 5 day 01 Days 1-5 6-8 1-14 Assessment Type Reason for assessment ARD window ARD Grace Days Payment Period 5 day 01 Days 1-5 6-8 1-14 14 day 02 Days 11-14 15-19 15-30 30 day 03 Days 21-29 30-34 31-60 60 day 04 Days 50-59 60-64 61-90 90 day 05 Days 80-89 90-94 91-100 NEW SCHEDULE Assessment Type Reason for assessment ARD window ARD Grace Days Payment Period 5 day 01 Days 1-5 6-8 1-14 14 day 02 Days 13-14 15-18 15-30 30 day 03 Days 27-29 30-33 31-60 60 day 04 Days 57-59 60-63 61-90 90 day 05 Days 87-89 90-93 91-100

CAUTION Make sure any assessments completed on or after 10/1/11 comply with the new assessment requirements For example ARD is set for 10/1/11 but this would be day 19 of the resident’s stay based on new schedule this assessment would be late and default rate would apply for days 15-18 – the same applies to ARD that would be too early

Scheduling your assessments If October 1st, 2011 is day 19, 34, 64 or 94 of the Medicare Part A stay, your ARD must be set no later than September 30th, 2011 in order to avoid payment penalties

TRANSITIONING This is the link to the transition for the FY2012 SNF PPS Policies as posted on the CMS website http://www.cms.gov/SNFPPS/Downloads/fy12transpolicymemo.pdf

Split Billing Periods If your billing is split between FY2011 and FY2012, RUG groups for both FY will be needed to establish payment for the entire period. The system was upgraded 9/18 to calculate both RUG groups. This will be reflected on your validation reports FY2011 error message = #1059 FY2012 error message = #1060

Combining Assessments SNF Must….. ARD for unscheduled PPS assessment falls within ARD window of a scheduled PPS assessment…. The scheduled assessment has not yet been completed….(ARD not set) Then the assessments MUST be combined

COMBINING ASSESSMENTS ARD = what would have been the ARD for the unscheduled assessment i.e. COT OMRA Item Set- Scheduled assessment item set – make sure to identify it as a combined assessment

End of Therapy with Resumption EOT OMRA End of Therapy OMRA EOT – R OMRA End of Therapy with Resumption

“REGARDLESS OF REASON” Three Day Policy If a resident classified in a RUG-IV Rehab + Extensive Services or a Rehab group does not receive any therapy services for “3 consecutive days” and EOT OMRA must be completed “REGARDLESS OF REASON”

EOT – OMRA ARD must be set on days 1,2 or 3 from the last day of therapy 3 days of missed therapy and no other skilled services being provided….. A non therapy RUG group will be billed/reimbursed for those days. Unless therapy will not be resumed, then the current EOT assessment guidelines apply.

EOT – ABN or NOMNC ABN or NOMNC does not need to be provided to the resident is the lapse in therapy is temporary and will resume. If therapy / skilled services will be terminated then the current ABN / NOMNC practices still apply

EOT-R OMRA – Not a new assessment New item in section “O” (O0450 A and B) Re-establishes the therapy rate if the resident resumes therapy at the same therapy level, No more than 5 days after the last day therapy received If therapy resumes after 5 days – SOT is still an option

EOT-R OMRA If your EOT assessment has not been accepted into the QIES ASAP system when therapy resumes, you will code section O0450 A and B and submit the combined assessment *COT Observation period re-starts on the date therapy is resumed

EOT-R OMRA If your EOT assessment has been accepted into the QIES ASAP system when therapy resumes; you will submit a modification request for that EOT OMRA with the only change being the completion of section O0450 A and B and check X0900E to indicate the reason for the modification is the resumption of therapy

THE NEW KID COT- OMRA Change of Therapy – Other Medicare Required Assessment

COT-OMRA COT observation required for all residents receiving therapy Successive 7 day observation periods Observation period starts the day after the ARD of the last PPS assessment used for payment EOT-R- COT observation period starts on the resumption date as stated on O0450B

When will a COT-OMRA be completed? Anytime there is a change in therapy provided, that changes the RUG-IV classification level on the most recent PPS assessment used for payment A change in ADLs score will not affect the RUG classification and will not require completion of a COT OMRA

One day of therapy = 15 minutes COT If a COT OMRA is completed, the payment adjustment will be retroactive to the 1st day of the observation period The ARD will be day 7 of the observation period One day of therapy = 15 minutes

What to look for RUG Category Minutes 1st Discipline 2nd Discipline Ultra High Rehab 720 5 days / week 3 days / week Very High Rehab 500 5 days/ week High Rehab 325 Medium Rehab 150 5 days of any combination of disciplines Low Rehab 45 3 days of any combination of disciplines 6 days/ week of 2 restorative nursing services

COMBINING ASSESSMENTS Look out for scheduled assessments and carefully plan your ARDs Example: Day 7 of the COT assessment falls within the ARD window (incl. grace days) of a scheduled PPS assessment and the ARD for the scheduled PPS assessment has not been set yet. You have determined that a COT OMRA is necessary you may choose to set the ARD for the scheduled assessment for an allowable day before day 7 of the COT observation period – this will re-set your observation period and your reimbursement rate.

REMEMBER COT OMRA will re-set reimbursement rate retroactively to the 1st day of the observation period this rate could be lower or higher

Out with the old, in with the new Group Therapy Redefined Old Definition Group Therapy Medicare Part A The treatment of 2 to 4 residents, regardless of payer source, who are performing similar activities, and are supervised by a therapist or assistant who is not supervising any other individuals

Group Therapy New Definition Group Therapy Medicare Part A The treatment of 4 residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or assistant who is not supervising any other individuals. NOTE: The minutes being coded on the MDS are unadjusted minutes, meaning, the minutes are coded in the MDS as the full time spent in therapy; however, the software grouper will allocate the minutes appropriately. In the case of group therapy, the minutes will be divided by 4.

PARTICIPATION The facility has scheduled a group therapy session and one of the residents is unable to attend or to stay for the entire session The group session can still be counted and the minutes will still be divided by four

Documentation Care Planning Skilled services, particularly therapy services, should be properly tailored to meet the individualized needs/goals of the patient Therapy type and modalities must be documented in the plan of care

DOCUMENTATION No specific documentation requirements to carry out COT observation / review No new assessments required when completing EOT-R

THERAPY SUPERVISION Effective October 1, 2011 Students are no longer required to be under line of sight supervision SNF can exercise their own judgment regarding supervision requirements Student treating resident/s while therapist is not treating or supervision someone else

Plan around new EOT policy Plan of Action Define your COT Observation process Plan around new EOT policy Schedule ARDs Carefully

Questions and Answers

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