When Should Skilled Nursing Facilities Complete End of Therapy OMRA?
With the October 1, 2010, implementation of the Minimum Data Set (MDS) 3.0, there appear to be challenges both in knowing when to complete an End of Therapy Other Medicare Required Assessment (EOT OMRA) and how that decision is going to affect billing of the claim.
The EOT OMRA is required to establish a new non-therapy Resource Utilization Group (RUG) classification and Medicare Part A Health Insurance Prospective Payment System (HIPPS) billing code or RUG-IV payment rate (Item Z0150A), which begins the day after the last day of therapy treatment. The Centers for Medicare & Medicaid Services’ (CMS) Resident Assessment Instrument (RAI) manual for MDS 3.0 completion states: “Use the unscheduled assessment Medicare non-therapy RUG (Z0150A) from the day after the latest therapy end date (O0400A6, B6, or C6) through the end of the standard payment period.” The selection of the assessment reference date (ARD) or the providing of therapy on a weekend does not affect when the billing change occurs.
The facility must complete an EOT OMRA with an ARD of 1–3 days after the last therapy treatment if the patient continues to receive skilled nursing services. If the facility does not provide weekend therapy services, the ARD is scheduled the next day therapy is normally provided. For example, if therapy ends on Thursday and the facility does not have weekend therapy services, the ARD could be set Friday, Monday or Tuesday (although there is no early assessment penalty if Saturday or Sunday are used). Medicare Part A payment changes the day after the last day of therapy.
For residents who receive therapy treatment on Friday and are then discharged from Medicare Part A on Monday, an EOT OMRA is required to bill at the non-therapy RUG classification for Saturday and Sunday. This will not be the case for unplanned discharges over the weekend. For example, if the resident is receiving therapy services and discharges to the hospital on Monday morning prior to therapy treatment, the EOT OMRA is not required as discharge was unplanned and therapy services are ongoing. The facility would code section O0400A6, B6 and/or C6 with dashes (–) to indicate therapy was ongoing at the time of discharge.
When a resident is calculated into a Rehab + Extensive or Rehab RUG group and therapy services are discontinued or not provided for three consecutive days, the facility must complete an EOT OMRA (if skilled nursing care continues) to have a non-therapy RUG for billing any days after the last therapy treatment.
When therapy services end and the resident does not need continued skilled nursing services, discharge from Medicare Part A coverage should be planned for the day after therapy services end. Facilities no longer have the luxury of keeping a resident on Medicare Part A for a few days after therapy ends to make discharge plans.
Good Interdisciplinary Team (IDT) communication skills and discharge planning are essential in efficient management of the Medicare program and to prevent provider liability. The IDT should be reviewing all Medicare Part A participants during weekly or more frequent Medicare utilization meetings. Key issues to discuss related to the EOT OMRA are:
- When is therapy ending?
- Does the resident continue to need skilled nursing services?
- When do we need to issue a Provider Notice of Non-Coverage letter, if at all?
Information regarding CMS guidance for completion of the EOT OMRA is available here.
For more on this issue, contact your BKD advisor or Brian Hickman at email@example.com.