1. 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

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

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

4. 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%

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

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

7. 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

8. 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 – the same applies to ARD that would be too early

9. 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

10. TRANSITIONING
This is the link to the transition for the FY2012 SNF PPS Policies as posted on the CMS website

11. 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

12. 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

13. 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

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

15. “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”

16. 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.

17. 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

18. 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

19. 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

20. 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

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

22. 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

23. 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

24. 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

25. 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

26. 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.

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

28. 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

29. 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.

30. 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

31. 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

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

33. 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

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

35. Questions and Answers

36. THANK YOU FOR ATTENDING