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The Medicare PPS Schedule:
Managing Early, Late, and Missed
PPS Assessments
HARMONY UNIVERSITY
The Provider Unit of
Harmony Healthcare International, Inc.
(HHI)
Presented by:
Beckie Dow, RN, RAC-MT
Director of MDS/Nursing Education & Training
Speaker Bio
Over 20 Years Experience in Long-term Care
Clinical and Reimbursement Accuracy in
Assessments
Quality Assurance Activities
Interrelation between MDS, Care Planning,
QA and Clinical Excellence at the Bedside
AANAC Master Trainer
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 2
The Medicare PPS Schedule:
Managing Early, Late, and Missed PPS Assessments
Disclosures: The planners and presenters of this educational activity
have no relationship with commercial entities or conflicts of interest
to disclose
Planners:
Elisa Bovee, MS, OTR/L
Diane Buckley, BSN, RN, RAC-CT
Beckie Dow, RN, RAC-MT
Keri Hart, MS CCC, SLP, RAC-CT
Kristen Mastrangelo, OTR/L, MBA, NHA
Christine Twombly, RNC, RAC-MT, LHRM
Presenter:
Beckie Dow, RN, RAC-MT, Director of MDS/Nursing Education &
Training
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 3
Harmony Healthcare International, Inc.
The Medicare PPS Schedule:
Managing Early, Late, and Missed PPS Assessments
Disclosure
Speaker:
Beckie Dow, RN, RAC-MT, Director of MDS/Nursing Program
Development
The speaker has no relevant financial
relationships to disclose
The speaker has no relevant nonfinancial
relationships to disclose
Copyright © 2013 All Rights Reserved 4
Harmony Healthcare International, Inc.
The Medicare PPS Schedule:
Managing Early, Late, and Missed PPS Assessments
Criteria for Successful Completion
Complete Sign-in and Sign-Out on
Attendance Form
Attendance for entire session
Completion and submission of
speaker evaluation form
Copyright © 2013 All Rights Reserved 5
Program Objectives
The learner will be able to outline the scheduled and
unscheduled PPS assessment requirements and ARD
selection requirements for each
The learner will be able to correctly identify the
application of default or provider liable days early, late,
or missed assessments
The learner will be able to identify appropriate use of
SOT, EOT, EOT-R, and COT assessments
The learner will be able to list the eight criteria for the
Medicare Short Stay assessment
The learner will be able to identify when to choose
Inactivation or Modification
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 6
Glossary of Terms
OMRA—Other Medicare Required
Assessment
PPS—Prospective Payment System
RUGs—Resource Utilization Groups
OBRA—Omnibus Reconciliation Act of
1987
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Medicare PPS Assessments
Scheduled Assessments
Set at regular intervals during the
Medicare stay
Unscheduled Assessments
Driven by clinical events that may occur
during the Medicare stay
Item set requirements will vary depending
on assessment type and assessment
combinations
Copyright © 2013 All Rights Reserved
Medicare PPS Assessments
Your software will create the correct
item set for you, based on coding in
Section A0310
Be able to choose what item set you
would need in case of computer failure
RAI Users Manual, Section 2.15
PPS assessments can be scheduled or
unscheduled
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 9
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SNF PPS MDS
Regularly Scheduled
MDS
Assessment/Typ
e
Assessme
nt
Reference
Date Grace Days
No. of Days
Coverage
Applicabl
e Days
5 Day /Return 1-5 6-8 14 1-14
14 Day 13-14 15-18 16 15-30
30 Day 27-29 30-33 30 31-60
60 Day 57-59 60-63 30 61-90
90 Day 87-89 90-93 10 91-100
PPS and OBRA MDS may be combined if ARD and completion date meet both requirements
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 11
Assessment Scheduling
One assessment may satisfy:
Two OBRA assessment requirements (such
as Quarterly and Discharge assessment)
An OBRA and PPS assessment (such as
Admission and 5 day PPS assessment)
Two PPS assessments (scheduled and
unscheduled)
The most stringent requirement of the two
assessments for MDS completion must be
met and the ARD windows must overlap
Copyright © 2013 All Rights Reserved
Assessment Scheduling Example:
How to Combine Two Assessments
24 25 26 27
Last day
of rehab
28 29 30
31 32 33 34 35 36 37
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EOT 1 EOT 3EOT 2
30-Day ARD Window
30-Day ARD Window
30-Day / EOT Window
Should I Code the Assessment as a
5-Day or Return/Readmission?
If a patient was on Medicare prior to
discharge to the hospital and upon
returning from the hospital the entry
tracker is coded “Reentry” (A1700 = 2),
then restart the PPS schedule with a
Return/Readmission Assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 13
Should I Code the Assessment as a
5-Day or Return/Readmission?
If a patient was on Medicare prior to
discharge to the hospital and upon
returning from the hospital, the entry
tracker is coded “Admission” (A1700 =
1), then restart the PPS schedule with a
5-Day Assessment
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Should I Code the assessment as a
5-Day or Return/Readmission?
When the patient is discharged from
Medicare but remains in the facility,
the OBRA assessment schedule
continues and, if Medicare resumes
within 30 days (without a hospital stay),
restart the PPS schedule with a 5-Day
Assessment
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START OF THERAPY (SOT) OMRA
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Start of Therapy (SOT) OMRA
A0310C = 1
Optional assessment
Completed only to classify a resident into a
Rehabilitation Plus Extensive Services or
Rehabilitation group (CMS will not accept a
nursing category only if the resident is not
already classified in a Rehab RUG)
ARD (Item A2300) must be set on days 5-7 after
the start of therapy
Medicare payment rate begins on the day therapy
started (O0400A5, B5, C5)
Must be completed within 14 days after the ARD
Copyright © 2013 All Rights Reserved
Start of Therapy (SOT) OMRA
A0310C = 1
1 2 3 4 5
PT Eval
30 min
Rx
6
PT
30 min
Rx
7
PT
30 min
Rx
8
5 Day
ARD
9
PT
30 min
Rx
10
PT
30 min
Rx
11
PT
30 min
Rx
12
PT
30 min
Rx
13
PT
30 min
Rx
14
15 16 17 18 19 20 21
SOT ARD Window
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Start of Therapy (SOT) OMRA
A0310C = 1 *SOT Not Indicated*
Copyright © 2013 All Rights Reserved 19Harmony Healthcare International, Inc.
1 2 3 4
PT Eval
&
30 min
Rx
5
PT
30 min
6
OT eval
&
30 min
Rx
7
OT
30 min
8
OT 30
min
5 Day
ARD
9 10 11 12 13 14
END OF THERAPY (EOT) OMRA
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 20
End of Therapy (EOT) OMRA
A0310C = 2
Required when the resident was classified in a RUG-
IV Rehabilitation Plus Extensive Services or
Rehabilitation group and continues to need Medicare
Part A SNF-level services after the discontinuation of
all therapies
ARD must be set on day 1, 2, or 3 after the last
treatment day
Must be completed within 14 days after the ARD
Establishes a new non-therapy RUG classification
and Medicare payment rate which begins the day
after the last day of therapy treatment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 21
End of Therapy (EOT) OMRA
A0310C = 2
1 2 3 4 5 6 7
8 9 10 11
Last
treatment
day
12 13 14
15
MC Ends
Patient
remains
in SNF
16 17 18 19 20 21
EOT ARD Window
Copyright © 2013 All Rights Reserved 22Harmony Healthcare International, Inc.
End of Therapy (EOT) OMRA
A0310C = 2
1
Last
treatment
day
2 3 4
Discharge
to home
5 6 7
8 9 10 11 12 13 14
15 16 17 18 19 20 21
EOT ARD Window
Copyright © 2013 All Rights Reserved 23Harmony Healthcare International, Inc.
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End of Therapy-Resumption
(EOT-R) OMRA
In cases where therapy resumes after the EOT
OMRA is performed and the resumption of
therapy date is no more than 5 consecutive
calendar days after the last day of therapy
provided, and the therapy services have
resumed at the same RUG-IV classification
level that had been in effect prior to the EOT
OMRA, an End of Therapy OMRA with
Resumption (EOT-R) may be completed
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End of Therapy-Resumption
(EOT-R) OMRA
1 2
OT/PT
3
OT/PT
4
OT/PT
5
OT/PT
6
OT/PT
7
8 9
OT/PT
10
OT/PT
11
OT/PT
12
Pt sick
13
Pt sick/
ER Eval
14
Pt sick
15
Pt sick
16
Pt sick
17
OT eval
and treat
18
OT
19
OT
20
OT
21
OT
EOT ARD Window
Copyright © 2013 All Rights Reserved 25Harmony Healthcare International, Inc.
End of Therapy-Resumption
(EOT-R) OMRA
1
OT/PT
2
OT/PT
3
OT/PT
4
OT/PT
5
OT/PT
6
OT/PT
7
OT/PT
8 9
OT/PT
10
OT/PT
11
OT/PT
12
Pt LOA
13
Pt
refused
14
Pt
refused
15
OT/PT
16
OT/PT
17
OT/PT
18
OT/PT
19
OT/PT
20
OT/PT
21
OT/PT
EOT ARD Window
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End of Therapy-Resumption
(EOT-R) OMRA
If the EOT OMRA without the EOT-R
items has been accepted into the QIES
ASAP system, then submit a
modification request for that EOT
OMRA with the only changes being
the completion of the EOT-R items
and check X0900E to indicate that the
reason for modification is the addition
of the Resumption of Therapy date
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CHANGE OF THERAPY (COT) OMRA
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Change of Therapy (COT) OMRA
A0310C = 4
Complete when the intensity of therapy, which
includes the total reimbursable therapy minutes
(RTM), and other therapy qualifiers such as
number of therapy days and disciplines
providing therapy, changes to such a degree that
the beneficiary would classify into a different
RUG-IV category for which the resident is
currently being billed for the 7-day COT
observation period following the ARD of the
most recent assessment used for Medicare
payment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 29
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Change of Therapy (COT) OMRA
A0310C = 4
Payment begins on Day 1 of the COT
observation period and continues for
the remainder of the current payment
period, unless the payment is modified
by a subsequent COT OMRA or other
(scheduled or unscheduled) PPS
assessment
Copyright © 2013 All Rights Reserved
Change of Therapy (COT) OMRA
A0310C = 4
The ARD of the COT is always Day 7 of
the rolling observation window
The rolling COT observation window
begins the day after the last assessment
used for PPS payment
If there is no change in the RUG another
rolling COT observation window
begins
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Change of Therapy (COT)
OMRA A0310C = 4
The exception is cases where the last
PPS Assessment was an EOT–R, the
end of the first COT observation period
is Day 7 after the Resumption of
Therapy date (O0450B) on the EOT-R,
rather than the ARD
In other words, the day of resumption
is Day 1 of the COT observation period
Copyright © 2013 All Rights Reserved
Change of Therapy (COT) OMRA
A0310C = 4
If a new assessment used for Medicare
payment has occurred, the COT
observation period will restart
beginning on the day following the
ARD of the most recent assessment
used for Medicare payment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 33
Change of Therapy (COT) OMRA
A0310C = 4
1 2 3 4 5 6 7
8
5d ARD
RUC
9 10 11 12 13 14
15
COT
Ckpoint
No RUG ∆
16 17 18
14d ARD
RUC
19 20 21
22 23 24 25
COT
Ckpoint
No RUG ∆
26 27
No Rx
28 No Rx
EOT &
30d ARD
29 No Rx 30
Therapy
resumes
31 32 33 34 35
36
No RUG
change
37 38 39 40 41 42
Change of Therapy Following the
(EOT-R) OMRA
15
OT/PT
16
OT/PT
17
Pt ill
18
Pt ill
19
Pt ill
20
OT/PT
Resumes
21
OT/PT
22
OT/PT
23
OT/PT
24
OT/PT
25
OT/PT
26
OT/PT
27
OT/PT
28
OT/PT
29
OT/PT
30
OT/PT
31
OT/PT
32
OT/PT
33
OT/PT
34
OT/PT
35
OT/PT
Copyright © 2013 All Rights Reserved 35Harmony Healthcare International, Inc.
EOT-R
ARD
COT
DAY 1
COT
DAY 2
COT
DAY 3
COT
DAY 4
COT
DAY 5
COT
DAY 6
COT
DAY 7
COT
ARD
Change of Therapy (COT) OMRA
A0310C = 4
In cases where a resident is discharged
from the SNF on or prior to day 7 of the
COT observation period, no COT OMRA
is required
If day 7 of the COT observation period
falls within the ARD window of a
scheduled PPS assessment the SNF may
choose to complete the PPS assessment
alone on or before day 7, resetting the
COT observation period
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 36
Change of Therapy (COT) OMRA
A0310C = 4
The SNF may also choose to combine
the COT OMRA and the scheduled PPS
assessment, provided that the ARD
requirements for both assessments are
met
The facility should choose the option
that leads to the best reimbursement
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 37
Change of Therapy (COT) OMRA
A0310C = 4
The SNF should ensure that a stand-
alone scheduled PPS assessment
replacing a COT is “used for payment”
Should the patient discharge from
Medicare services prior to the
scheduled assessment being “used for
payment” the facility will be provider
liable for the number of days the COT is
out of compliance (missed assessment)
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Change of Therapy (COT) OMRA
A0310C = 4
20
COT
Ckpt
21 22 23 24 25 26
27
COT
Ckpt
PPS ARD
28 29 30 31 32 33
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 39
COT
Required
PPS
ARD
Pt
D/C
PROVIDER LIABLE
PROVIDER LIABLE
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Assessment Combination
A Medicare unscheduled assessment in a
scheduled assessment window cannot be
followed by the scheduled assessment later in
that window
The two assessments must be combined with
an ARD appropriate to the unscheduled
assessment
Or, the facility can choose to do the stand-
alone scheduled assessment prior to or on
day 7 of the COT look-back window
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Harmony Healthcare International, Inc. 41
Assessment Combination
If a scheduled assessment has been
completed and an unscheduled
assessment falls in that assessment
window, the unscheduled assessment
may supersede the scheduled
assessment and the payment may be
modified until the next unscheduled or
scheduled assessment
Copyright © 2013 All Rights Reserved
COT Impact on Not Combining
Assessments
Example:
COT ARD Day 13
14 day ARD Day 15
The COT OMRA will begin paying on PPS
Day 7 (day 1 of the COT observation
period) and continue until the next
assessment used for payment
The 14 day assessment will not be used
for payment
The next COT checkpoint will be Day 20
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EARLY, LATE, OR MISSED PPS
ASSESSMENTS
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Early PPS Assessment
Scheduled Assessment: If an
assessment is performed earlier than
the schedule indicates the provider will
be paid at default rate the number of
days the assessment was out of
compliance
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 44
Early PPS Assessment
Example: A Medicare-required 14-Day
assessment with an ARD of day 12 (one
day early) would be paid at the default
rate for the first day of the payment
period that begins on day 15
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 45
Early PPS Assessment
Unscheduled Assessment: In the case
of an early COT OMRA, the early COT
would reset the COT calendar
The next COT OMRA look back period
will end seven days after the early COT
OMRA ARD
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 46
Early PPS Assessment
Example:
COT ARD due on day 42
Facility sets COT ARD on day 40 (early)
Facility will be paid at default rate for two
days (number of days early)
Next COT ARD will begin on day 41 and
end on day 47 (set from erroneous ARD)
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 47
COT
ARD
due
COT
count
Day 2
Early PPS Assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 48
32 33 34 35 36 37 38
39 40 41 42 43 44 45
46 47 48 49 50 51 52
COT
ARD
Set
Default Rate
COT
ARD
Due
COT
Day 1
COT
Day 2
COT
Day 3
COT
Day 4
COT
Day 5
COT
Day 6
COT
Day 7
Late PPS Assessment
If the SNF fails to set the ARD within
the defined ARD window for a
Medicare-required assessment,
including the grace days, and the
resident is still on Part A, the SNF must
still complete a late assessment
The ARD can be no later than the day
the error was identified
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 49
Late PPS Assessment
If the ARD on the late assessment is set
for prior to the end of the period during
which the late assessment would have
controlled payment, and no intervening
assessments have occurred, the SNF
would bill the default rate for the
number of days that the assessment is
out of compliance, including the ARD
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 50
Late PPS Assessment
The SNF would then bill the HIPPS
code established by the late assessment
by the late assessment for the remaining
period of time that the assessment
would have controlled payment
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Late PPS Assessment
An intervening assessment refers to an
assessment with an ARD set for a day in
the interim period between the last day
of the appropriate ARD window for a
late assessment (including grace days,
when appropriate) and the actual ARD
of the late assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 52
Late PPS Assessment
Example: A Medicare-required 30-day
assessment with an ARD of Day 41 is
out of compliance for 8 days
Facility will bill default rate for 8 days
The HIPPS code from the late 30-day
assessment controls payment for the
remaining 22 days of the assessment
period, unless there is an intervening
assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 53
Late PPS Assessment
If the ARD of the late assessment is set
after the end of the period during which
the late assessment would have
controlled payment, or if an intervening
assessment has occurred, the provider
must still complete the assessment
The ARD can be no earlier than the day
the error was identified
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 54
Late PPS Assessment
The SNF will bill all covered days
during which the late assessment
would have controlled payment at the
default rate regardless of the HIPPS
code calculated from the late
assessment
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Late PPS Assessment
Example #1: A Medicare-required 14-
Day assessment with an ARD of Day 32
would be paid at the default rate for
days 15 through 30
The late 14-Day assessment cannot be
used to replace a different Medicare-
required assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 56
Late PPS Assessment
Example #1, continued
The SNF will still be required to complete
the 30-day assessment within days 27-33
The 30-Day assessment would cover Days
31 through 60 if Medicare eligibility
requirements continued to be met
The 14-Day assessment is required to be
completed, but will not be used for
payment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 57
Late PPS Assessment
Example # 2: A 30-Day assessment is
completed with an ARD of Day 30
Day 7 of the COT observation period = Day
37…but the COT assessment is not done
An EOT OMRA is performed timely with an
ARD of day 42 (last rehab treatment provided
on day 39)
On Day 52 the facility determines that a COT
should have been completed with an ARD of
day 37…the COT is now a late assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 58
Late PPS Assessment
Example #2 (Continued)
The ARD for the (late) COT is set for day
52…the day the error was discovered
The late COT would have controlled
payment from day 31 until the next
assessment used for payment, had it been
timely
The EOT OMRA is an intervening
assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 59
Late PPS Assessment
Example #2 (Cont.)
The facility will bill default for 9 days
(period COT would have controlled)
The facility will bill the HIPPS code
from the EOT OMRA as per normal,
beginning the first non-therapy day,
until the next scheduled or unscheduled
assessment used for payment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 60
Missed PPS Assessment
If the SNF fails to set the ARD of a
scheduled PPS assessment prior to the
end of the last day of the ARD window
and the resident was already
discharged from Medicare Part A when
the error is discovered the provider
cannot complete and assessment and
the days cannot be billed to Medicare A
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 61
Missed PPS Assessment
In some cases, an existing OBRA
assessment (except a stand-alone
discharge assessment) in the QIES
ASAP system may be used to bill for
some Part A days when specific
circumstances are met
See RAI User’s Manual pages 6-54 & 55
(Version 1.11, October 2013)
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 62
Missed PPS Assessment
In the case of an unscheduled PPS
assessment if the SNF fails to set the
ARD for an unscheduled PPS
assessment within the defined ARD
window and the resident is discharged
from Part A the assessment is missed
and cannot be completed
All days are provider-liable
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 63
Missed PPS Assessment
A missed unscheduled PPS assessment
will have all days paid at provider-
liable until an intervening assessment
controls the payment
The intervening assessment will control
payment until another assessment
payment block begins
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 64
65
Harmony Healthcare International, Inc.
OMRAs: Setting the ARD
For the Change of Therapy (COT) OMRA,
End of Therapy (EOT) OMRA, and Start of
Therapy (SOT) OMRA, the decision for which
day within the allowable ARD window the
ARD of the assessment will be set may be
made up to two days after the window has
passed
These are not additional grace days that may
be chosen as the ARD
These are additional days to “open” the MDS
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Harmony Healthcare International, Inc. 66
Completing Resident Interviews
on Stand-alone OMRAs
Providers are encouraged to complete
resident interviews in as timely a
manner and as complete as possible
Interviews for OMRAs may occur one
to two days after the ARD
CMS expects most OMRAs will not
catch providers by surprise
Copyright © 2013 All Rights Reserved
Interviews for Stand-Alone EOT, COT
and SOT OMRAs
On the day the interview would be
conducted, the assessor may refer back to the
previous scheduled or unscheduled
assessment and determine if the date of the
interview is within 14 days
If the date noted is within 14 days of when
this interview was to be done, the prior
information may be used so long as the
person who conducted the prior interview is
available to sign the current assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 67
Interviews for Stand-Alone EOT,
COT and SOT OMRAs - Example
30-day assessment ARD was March 10
Interview date (as noted in Z0400) was March 8
COT observation period ends on March 17
If the team determines that a COT is required
the interview from the 30 day may be carried
forward to the unscheduled assessment
ARD of COT and the date the interviews
would be conducted = March 17
Date in Z0400 = March 8
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 68
Interviews for Stand-Alone EOT,
COT and SOT OMRAs - Example
30-day assessment ARD was March 10
Interview date (as noted in Z0400) was March 8
First COT observation period ends on March 17
– no COT required
Next COT observation period ends on March 24
– team determined that the COT was required
Interviews form the 30 day may not be carried
forward from the prior assessment
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 69
Interviews for Stand-Alone EOT,
COT and SOT OMRAs
Key points:
The person who conducted the original
interview must be available to sign the
current assessment in Z0400
The date of the original interview will be
put in Z0400 of the current assessment
The clinical status of the resident must not
have changed
This only applies to resident interviews,
not staff assessments
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 70
Medical Leave of Absence (MLOA)
For scheduled PPS assessments the Medicare
assessment schedule is adjusted to exclude
the LOA when determining the appropriate
ARD for an assessment
For unscheduled PPS assessments the ARD
of the assessment is not adjusted for an LOA,
because ARDs for unscheduled assessments
are not tied to any particular Medicare day
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 71
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Medical Leave of Absence (MLOA)
If a resident is out of the facility over a
midnight, but for less than 24 hours, and is
not admitted, the Medicare assessment
schedule is not restarted
However, there are payment implications: the
day preceding the midnight on which the
resident was absent from the nursing home is
not a covered Part A day
Becomes Medicare “skip day”
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 73
Resident Discharged On or
Before Eighth Day of SNF Stay
If the beneficiary dies, is discharged from the
SNF, or discharged from Part A level of care
before the eighth day of covered SNF stay, the
resident may be a candidate for the Short-
Stay Policy
The Short-Stay Policy allows the
assignment into a Rehabilitation Plus
Extensive Services or Rehabilitation
category when a resident was not able to
receive 5 days of therapy
Copyright © 2013 All Rights Reserved
Medicare Short-Stay Assessment
1. The assessment must be a Start of Therapy
OMRA A0310C = 1 or 3
2. A PPS 5-day or re-admission return
assessment must be complete (may be
combined)
3. The ARD (A2300) must be on or before the
8th day of the Part A Medicare covered stay
The ARD minus the start of Medicare stay
date (A2400B) must be 7 days or less
Harmony Healthcare International, Inc. 74Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 75
Medicare Short-Stay Assessment
4. The ARD (A2300) of the Start of Therapy
OMRA must be the last covered Medicare
Part A day. The Start of Therapy OMRA
ARD must equal the end of Medicare stay
date (A2400C). The end of the Medicare
stay date is the date Part A ended
**See instructions for A2400C in Chapter 3 for
more detail
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 76
Medicare Short-Stay Assessment
5. The ARD (A2300) of the Start of Therapy
OMRA may not be more than 3 days after
the start of therapy date not including the
Start of Therapy date
6. Rehabilitation therapy (Speech-Language
Pathology services, Occupational
Therapy, or physical therapy) started
during the last 4 days of the Medicare
Part A covered stay (including weekends)
Copyright © 2013 All Rights Reserved
Medicare Short-Stay Assessment
7. At least one therapy discipline
continued through the last day of the
Medicare Part A covered stay
8. The RUG group assigned to the Start
of Therapy OMRA must be
Rehabilitation Plus Extensive Services
or a Rehabilitation group (Z0100A)
Harmony Healthcare International, Inc. 77Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 78
Medicare Short-Stay Assessment
If all eight of these conditions are met, then
the assignment of the RUG-IV rehabilitation
therapy classification is calculated based on
average daily minutes actually provided, and
the resulting RUG-IV group is recorded in
MDS item Z0100A (Medicare Part A HIPPS
Code)
Payment begins the date of the first therapy
evaluation through date of discharge
Use the Short Stay Algorithm
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 79
RUG-IV Rehab Categories
Short-Stay Assessment
15-29 average daily therapy minutes = RL_
30-64 average daily therapy minutes = RM_
65-99 average daily therapy minutes = RH_
100-143 average daily therapy minutes = RV_
=/> 144 average daily therapy minutes = RU_
Copyright © 2013 All Rights Reserved
MDS Correction Process
Considerations
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 80
Harmony Healthcare International, Inc. 81
MDS Correction
Errors that inaccurately reflect the resident’s clinical
status and/or result in an inappropriate plan of care
are considered significant errors (used to be called
“major” errors)
Correct via OBRA significant correction MDS
Must also modify previous assessment while in
process
Most corrections are minor
All other errors related to the coding of MDS items
are considered minor errors
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 82
MDS Correction
If an minor error is discovered in a record in
that has been submitted, Modification or
Inactivation procedures must be
implemented by the provider for correction:
Must be corrected within 14 days after
identifying the errors
Transcription errors, data entry errors,
software product errors, or item coding
errors can be modified
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 83
Modification
A Modification request moves the
inaccurate record into history in MDS
database and replaces it with the
corrected record as the active record
Most MDS item errors can be corrected
via modification process
Modification does not require that a
new assessment be completed
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 84
Modification
Modification correction request is Section X:
Item A0050, Type of Record, should have a
value of 2 or 3, indicating a modification
request (New for April 1st, 2012)
2 = Modify existing record
3 = Inactivate existing record
Assessors must be sure to replicate the
information exactly as it appeared on the
erroneous record!
Copyright © 2013 All Rights Reserved
Harmony Healthcare International, Inc. 85
Inactivation
An Inactivation request also moves the inaccurate
record into history of the MDS database but does not
replace it with a new record.
Must send a new assessment to replace (if
assessment was required)
Records based on an event that did not occur
(e.g., the record submitted does not correspond to
any actual event) will not require a replacement
For example, a discharge record was submitted for
a resident but there was no actual discharge; thus,
there was no event
Copyright © 2013 All Rights Reserved
Inactivation vs. Modification
As of May 2013 providers may correct
some fields via the modification process
that were previously only able to be
corrected via inactivation
The ARD can be changed only when the
ARD on the assessment represents a data
entry/typographical error, and only if it
does not result in a change in the look-
back period that was considered while
completing the assessment
Harmony Healthcare International, Inc. 86Copyright © 2013 All Rights Reserved
Inactivation vs. Modification
The Type of Assessment items (A0310)
can be modified if the Item Set Code
(ISC) of that assessment does not
change
If the item subset would change, a
modification cannot be done
Full list of item subsets can be found in
the RAI Users Manual, section 2.5
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 87
Inactivation vs. Modification
Type of Provider (A0200) cannot be
modified
Type of Provider (A0200) errors must be
corrected via inactivation and submission
of a new MDS assessment
PPS stand alone assessments will only
require modification, not inactivation
PPS and OBRA combined assessments
may require modification or inactivation
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 88
Harmony Healthcare International, Inc. 89
MDS Correction
Correction of these items requires a
Special Manual Record correction:
Submission Requirement (A0410)
State-assigned facility submission ID
(FAC_ID)
Production/test code (PRODN_TEST_CD)
The facility must submit a written
request to the state MDS Coordinator to
have the problems fixed
Copyright © 2013 All Rights Reserved
Final Thoughts…
Proactive management of the PPS
schedule is the key to successful
management
Daily communication between Therapy
department and MDS department
about potential for unscheduled
assessments and ARD dates
Use a 100 day tracker
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 90
Final Thoughts…
Strategic selection of ARDs and
assessment types
Careful monitoring of provision of
Therapy minutes to ensure the patient
is on track for the planned intensity
Timely opening and completion of MDS
assessments
Up-to-date RAI User’s Manual and use
your Harmony consultant as a resource
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 91
References
RAI Users Manual version 1.11
(October 2013)
Medicare Claims Processing Manual
Chapter 30
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 92
Questions/Answers
Harmony Healthcare International
1 (800) 530 – 4413
Bdow@harmony-healthcare.com
Harmony Healthcare International, Inc. 9393Copyright © 2013 All Rights Reserved
Harmony Healthcare International
Have you Considered a Customized Complimentary
HARMONY(HHI) MEDICARE PROGRAM
EVALUATION
or
CASE MIX ANALYSIS
for your Facility?
Perhaps your facility has potential for additional revenue
Assess your facility against key indicators and national norms
Email us at for more information
RUGS@harmony-healthcare.com
Analysis is cost & obligation free
Harmony Healthcare International, Inc. 94Copyright © 2013 All Rights Reserved

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Medicare PPS Schedule: Managing Early, Late, and Missed PPS Assessments

  • 1. The Medicare PPS Schedule: Managing Early, Late, and Missed PPS Assessments HARMONY UNIVERSITY The Provider Unit of Harmony Healthcare International, Inc. (HHI) Presented by: Beckie Dow, RN, RAC-MT Director of MDS/Nursing Education & Training
  • 2. Speaker Bio Over 20 Years Experience in Long-term Care Clinical and Reimbursement Accuracy in Assessments Quality Assurance Activities Interrelation between MDS, Care Planning, QA and Clinical Excellence at the Bedside AANAC Master Trainer Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 2
  • 3. The Medicare PPS Schedule: Managing Early, Late, and Missed PPS Assessments Disclosures: The planners and presenters of this educational activity have no relationship with commercial entities or conflicts of interest to disclose Planners: Elisa Bovee, MS, OTR/L Diane Buckley, BSN, RN, RAC-CT Beckie Dow, RN, RAC-MT Keri Hart, MS CCC, SLP, RAC-CT Kristen Mastrangelo, OTR/L, MBA, NHA Christine Twombly, RNC, RAC-MT, LHRM Presenter: Beckie Dow, RN, RAC-MT, Director of MDS/Nursing Education & Training Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 3
  • 4. Harmony Healthcare International, Inc. The Medicare PPS Schedule: Managing Early, Late, and Missed PPS Assessments Disclosure Speaker: Beckie Dow, RN, RAC-MT, Director of MDS/Nursing Program Development The speaker has no relevant financial relationships to disclose The speaker has no relevant nonfinancial relationships to disclose Copyright © 2013 All Rights Reserved 4
  • 5. Harmony Healthcare International, Inc. The Medicare PPS Schedule: Managing Early, Late, and Missed PPS Assessments Criteria for Successful Completion Complete Sign-in and Sign-Out on Attendance Form Attendance for entire session Completion and submission of speaker evaluation form Copyright © 2013 All Rights Reserved 5
  • 6. Program Objectives The learner will be able to outline the scheduled and unscheduled PPS assessment requirements and ARD selection requirements for each The learner will be able to correctly identify the application of default or provider liable days early, late, or missed assessments The learner will be able to identify appropriate use of SOT, EOT, EOT-R, and COT assessments The learner will be able to list the eight criteria for the Medicare Short Stay assessment The learner will be able to identify when to choose Inactivation or Modification Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 6
  • 7. Glossary of Terms OMRA—Other Medicare Required Assessment PPS—Prospective Payment System RUGs—Resource Utilization Groups OBRA—Omnibus Reconciliation Act of 1987 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 7
  • 8. Harmony Healthcare International, Inc. 8 Medicare PPS Assessments Scheduled Assessments Set at regular intervals during the Medicare stay Unscheduled Assessments Driven by clinical events that may occur during the Medicare stay Item set requirements will vary depending on assessment type and assessment combinations Copyright © 2013 All Rights Reserved
  • 9. Medicare PPS Assessments Your software will create the correct item set for you, based on coding in Section A0310 Be able to choose what item set you would need in case of computer failure RAI Users Manual, Section 2.15 PPS assessments can be scheduled or unscheduled Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 9
  • 10. Harmony Healthcare International, Inc. 10 SNF PPS MDS Regularly Scheduled MDS Assessment/Typ e Assessme nt Reference Date Grace Days No. of Days Coverage Applicabl e Days 5 Day /Return 1-5 6-8 14 1-14 14 Day 13-14 15-18 16 15-30 30 Day 27-29 30-33 30 31-60 60 Day 57-59 60-63 30 61-90 90 Day 87-89 90-93 10 91-100 PPS and OBRA MDS may be combined if ARD and completion date meet both requirements Copyright © 2013 All Rights Reserved
  • 11. Harmony Healthcare International, Inc. 11 Assessment Scheduling One assessment may satisfy: Two OBRA assessment requirements (such as Quarterly and Discharge assessment) An OBRA and PPS assessment (such as Admission and 5 day PPS assessment) Two PPS assessments (scheduled and unscheduled) The most stringent requirement of the two assessments for MDS completion must be met and the ARD windows must overlap Copyright © 2013 All Rights Reserved
  • 12. Assessment Scheduling Example: How to Combine Two Assessments 24 25 26 27 Last day of rehab 28 29 30 31 32 33 34 35 36 37 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 12 EOT 1 EOT 3EOT 2 30-Day ARD Window 30-Day ARD Window 30-Day / EOT Window
  • 13. Should I Code the Assessment as a 5-Day or Return/Readmission? If a patient was on Medicare prior to discharge to the hospital and upon returning from the hospital the entry tracker is coded “Reentry” (A1700 = 2), then restart the PPS schedule with a Return/Readmission Assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 13
  • 14. Should I Code the Assessment as a 5-Day or Return/Readmission? If a patient was on Medicare prior to discharge to the hospital and upon returning from the hospital, the entry tracker is coded “Admission” (A1700 = 1), then restart the PPS schedule with a 5-Day Assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 14
  • 15. Should I Code the assessment as a 5-Day or Return/Readmission? When the patient is discharged from Medicare but remains in the facility, the OBRA assessment schedule continues and, if Medicare resumes within 30 days (without a hospital stay), restart the PPS schedule with a 5-Day Assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 15
  • 16. START OF THERAPY (SOT) OMRA Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 16
  • 17. Harmony Healthcare International, Inc. 17 Start of Therapy (SOT) OMRA A0310C = 1 Optional assessment Completed only to classify a resident into a Rehabilitation Plus Extensive Services or Rehabilitation group (CMS will not accept a nursing category only if the resident is not already classified in a Rehab RUG) ARD (Item A2300) must be set on days 5-7 after the start of therapy Medicare payment rate begins on the day therapy started (O0400A5, B5, C5) Must be completed within 14 days after the ARD Copyright © 2013 All Rights Reserved
  • 18. Start of Therapy (SOT) OMRA A0310C = 1 1 2 3 4 5 PT Eval 30 min Rx 6 PT 30 min Rx 7 PT 30 min Rx 8 5 Day ARD 9 PT 30 min Rx 10 PT 30 min Rx 11 PT 30 min Rx 12 PT 30 min Rx 13 PT 30 min Rx 14 15 16 17 18 19 20 21 SOT ARD Window Copyright © 2013 All Rights Reserved 18Harmony Healthcare International, Inc.
  • 19. Start of Therapy (SOT) OMRA A0310C = 1 *SOT Not Indicated* Copyright © 2013 All Rights Reserved 19Harmony Healthcare International, Inc. 1 2 3 4 PT Eval & 30 min Rx 5 PT 30 min 6 OT eval & 30 min Rx 7 OT 30 min 8 OT 30 min 5 Day ARD 9 10 11 12 13 14
  • 20. END OF THERAPY (EOT) OMRA Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 20
  • 21. End of Therapy (EOT) OMRA A0310C = 2 Required when the resident was classified in a RUG- IV Rehabilitation Plus Extensive Services or Rehabilitation group and continues to need Medicare Part A SNF-level services after the discontinuation of all therapies ARD must be set on day 1, 2, or 3 after the last treatment day Must be completed within 14 days after the ARD Establishes a new non-therapy RUG classification and Medicare payment rate which begins the day after the last day of therapy treatment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 21
  • 22. End of Therapy (EOT) OMRA A0310C = 2 1 2 3 4 5 6 7 8 9 10 11 Last treatment day 12 13 14 15 MC Ends Patient remains in SNF 16 17 18 19 20 21 EOT ARD Window Copyright © 2013 All Rights Reserved 22Harmony Healthcare International, Inc.
  • 23. End of Therapy (EOT) OMRA A0310C = 2 1 Last treatment day 2 3 4 Discharge to home 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 EOT ARD Window Copyright © 2013 All Rights Reserved 23Harmony Healthcare International, Inc.
  • 24. Harmony Healthcare International, Inc. 24 End of Therapy-Resumption (EOT-R) OMRA In cases where therapy resumes after the EOT OMRA is performed and the resumption of therapy date is no more than 5 consecutive calendar days after the last day of therapy provided, and the therapy services have resumed at the same RUG-IV classification level that had been in effect prior to the EOT OMRA, an End of Therapy OMRA with Resumption (EOT-R) may be completed Copyright © 2013 All Rights Reserved
  • 25. End of Therapy-Resumption (EOT-R) OMRA 1 2 OT/PT 3 OT/PT 4 OT/PT 5 OT/PT 6 OT/PT 7 8 9 OT/PT 10 OT/PT 11 OT/PT 12 Pt sick 13 Pt sick/ ER Eval 14 Pt sick 15 Pt sick 16 Pt sick 17 OT eval and treat 18 OT 19 OT 20 OT 21 OT EOT ARD Window Copyright © 2013 All Rights Reserved 25Harmony Healthcare International, Inc.
  • 26. End of Therapy-Resumption (EOT-R) OMRA 1 OT/PT 2 OT/PT 3 OT/PT 4 OT/PT 5 OT/PT 6 OT/PT 7 OT/PT 8 9 OT/PT 10 OT/PT 11 OT/PT 12 Pt LOA 13 Pt refused 14 Pt refused 15 OT/PT 16 OT/PT 17 OT/PT 18 OT/PT 19 OT/PT 20 OT/PT 21 OT/PT EOT ARD Window Copyright © 2013 All Rights Reserved 26Harmony Healthcare International, Inc.
  • 27. Harmony Healthcare International, Inc. 27 End of Therapy-Resumption (EOT-R) OMRA If the EOT OMRA without the EOT-R items has been accepted into the QIES ASAP system, then submit a modification request for that EOT OMRA with the only changes being the completion of the EOT-R items and check X0900E to indicate that the reason for modification is the addition of the Resumption of Therapy date Copyright © 2013 All Rights Reserved
  • 28. CHANGE OF THERAPY (COT) OMRA Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 28
  • 29. Change of Therapy (COT) OMRA A0310C = 4 Complete when the intensity of therapy, which includes the total reimbursable therapy minutes (RTM), and other therapy qualifiers such as number of therapy days and disciplines providing therapy, changes to such a degree that the beneficiary would classify into a different RUG-IV category for which the resident is currently being billed for the 7-day COT observation period following the ARD of the most recent assessment used for Medicare payment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 29
  • 30. Harmony Healthcare International, Inc. 30 Change of Therapy (COT) OMRA A0310C = 4 Payment begins on Day 1 of the COT observation period and continues for the remainder of the current payment period, unless the payment is modified by a subsequent COT OMRA or other (scheduled or unscheduled) PPS assessment Copyright © 2013 All Rights Reserved
  • 31. Change of Therapy (COT) OMRA A0310C = 4 The ARD of the COT is always Day 7 of the rolling observation window The rolling COT observation window begins the day after the last assessment used for PPS payment If there is no change in the RUG another rolling COT observation window begins Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 31
  • 32. Harmony Healthcare International, Inc. 32 Change of Therapy (COT) OMRA A0310C = 4 The exception is cases where the last PPS Assessment was an EOT–R, the end of the first COT observation period is Day 7 after the Resumption of Therapy date (O0450B) on the EOT-R, rather than the ARD In other words, the day of resumption is Day 1 of the COT observation period Copyright © 2013 All Rights Reserved
  • 33. Change of Therapy (COT) OMRA A0310C = 4 If a new assessment used for Medicare payment has occurred, the COT observation period will restart beginning on the day following the ARD of the most recent assessment used for Medicare payment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 33
  • 34. Change of Therapy (COT) OMRA A0310C = 4 1 2 3 4 5 6 7 8 5d ARD RUC 9 10 11 12 13 14 15 COT Ckpoint No RUG ∆ 16 17 18 14d ARD RUC 19 20 21 22 23 24 25 COT Ckpoint No RUG ∆ 26 27 No Rx 28 No Rx EOT & 30d ARD 29 No Rx 30 Therapy resumes 31 32 33 34 35 36 No RUG change 37 38 39 40 41 42
  • 35. Change of Therapy Following the (EOT-R) OMRA 15 OT/PT 16 OT/PT 17 Pt ill 18 Pt ill 19 Pt ill 20 OT/PT Resumes 21 OT/PT 22 OT/PT 23 OT/PT 24 OT/PT 25 OT/PT 26 OT/PT 27 OT/PT 28 OT/PT 29 OT/PT 30 OT/PT 31 OT/PT 32 OT/PT 33 OT/PT 34 OT/PT 35 OT/PT Copyright © 2013 All Rights Reserved 35Harmony Healthcare International, Inc. EOT-R ARD COT DAY 1 COT DAY 2 COT DAY 3 COT DAY 4 COT DAY 5 COT DAY 6 COT DAY 7 COT ARD
  • 36. Change of Therapy (COT) OMRA A0310C = 4 In cases where a resident is discharged from the SNF on or prior to day 7 of the COT observation period, no COT OMRA is required If day 7 of the COT observation period falls within the ARD window of a scheduled PPS assessment the SNF may choose to complete the PPS assessment alone on or before day 7, resetting the COT observation period Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 36
  • 37. Change of Therapy (COT) OMRA A0310C = 4 The SNF may also choose to combine the COT OMRA and the scheduled PPS assessment, provided that the ARD requirements for both assessments are met The facility should choose the option that leads to the best reimbursement Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 37
  • 38. Change of Therapy (COT) OMRA A0310C = 4 The SNF should ensure that a stand- alone scheduled PPS assessment replacing a COT is “used for payment” Should the patient discharge from Medicare services prior to the scheduled assessment being “used for payment” the facility will be provider liable for the number of days the COT is out of compliance (missed assessment) Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 38
  • 39. Change of Therapy (COT) OMRA A0310C = 4 20 COT Ckpt 21 22 23 24 25 26 27 COT Ckpt PPS ARD 28 29 30 31 32 33 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 39 COT Required PPS ARD Pt D/C PROVIDER LIABLE PROVIDER LIABLE
  • 40. Harmony Healthcare International, Inc. 40 Assessment Combination A Medicare unscheduled assessment in a scheduled assessment window cannot be followed by the scheduled assessment later in that window The two assessments must be combined with an ARD appropriate to the unscheduled assessment Or, the facility can choose to do the stand- alone scheduled assessment prior to or on day 7 of the COT look-back window Copyright © 2013 All Rights Reserved
  • 41. Harmony Healthcare International, Inc. 41 Assessment Combination If a scheduled assessment has been completed and an unscheduled assessment falls in that assessment window, the unscheduled assessment may supersede the scheduled assessment and the payment may be modified until the next unscheduled or scheduled assessment Copyright © 2013 All Rights Reserved
  • 42. COT Impact on Not Combining Assessments Example: COT ARD Day 13 14 day ARD Day 15 The COT OMRA will begin paying on PPS Day 7 (day 1 of the COT observation period) and continue until the next assessment used for payment The 14 day assessment will not be used for payment The next COT checkpoint will be Day 20 Harmony Healthcare International, Inc. 42Copyright © 2013 All Rights Reserved
  • 43. EARLY, LATE, OR MISSED PPS ASSESSMENTS Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 43
  • 44. Early PPS Assessment Scheduled Assessment: If an assessment is performed earlier than the schedule indicates the provider will be paid at default rate the number of days the assessment was out of compliance Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 44
  • 45. Early PPS Assessment Example: A Medicare-required 14-Day assessment with an ARD of day 12 (one day early) would be paid at the default rate for the first day of the payment period that begins on day 15 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 45
  • 46. Early PPS Assessment Unscheduled Assessment: In the case of an early COT OMRA, the early COT would reset the COT calendar The next COT OMRA look back period will end seven days after the early COT OMRA ARD Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 46
  • 47. Early PPS Assessment Example: COT ARD due on day 42 Facility sets COT ARD on day 40 (early) Facility will be paid at default rate for two days (number of days early) Next COT ARD will begin on day 41 and end on day 47 (set from erroneous ARD) Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 47
  • 48. COT ARD due COT count Day 2 Early PPS Assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 48 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 COT ARD Set Default Rate COT ARD Due COT Day 1 COT Day 2 COT Day 3 COT Day 4 COT Day 5 COT Day 6 COT Day 7
  • 49. Late PPS Assessment If the SNF fails to set the ARD within the defined ARD window for a Medicare-required assessment, including the grace days, and the resident is still on Part A, the SNF must still complete a late assessment The ARD can be no later than the day the error was identified Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 49
  • 50. Late PPS Assessment If the ARD on the late assessment is set for prior to the end of the period during which the late assessment would have controlled payment, and no intervening assessments have occurred, the SNF would bill the default rate for the number of days that the assessment is out of compliance, including the ARD Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 50
  • 51. Late PPS Assessment The SNF would then bill the HIPPS code established by the late assessment by the late assessment for the remaining period of time that the assessment would have controlled payment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 51
  • 52. Late PPS Assessment An intervening assessment refers to an assessment with an ARD set for a day in the interim period between the last day of the appropriate ARD window for a late assessment (including grace days, when appropriate) and the actual ARD of the late assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 52
  • 53. Late PPS Assessment Example: A Medicare-required 30-day assessment with an ARD of Day 41 is out of compliance for 8 days Facility will bill default rate for 8 days The HIPPS code from the late 30-day assessment controls payment for the remaining 22 days of the assessment period, unless there is an intervening assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 53
  • 54. Late PPS Assessment If the ARD of the late assessment is set after the end of the period during which the late assessment would have controlled payment, or if an intervening assessment has occurred, the provider must still complete the assessment The ARD can be no earlier than the day the error was identified Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 54
  • 55. Late PPS Assessment The SNF will bill all covered days during which the late assessment would have controlled payment at the default rate regardless of the HIPPS code calculated from the late assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 55
  • 56. Late PPS Assessment Example #1: A Medicare-required 14- Day assessment with an ARD of Day 32 would be paid at the default rate for days 15 through 30 The late 14-Day assessment cannot be used to replace a different Medicare- required assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 56
  • 57. Late PPS Assessment Example #1, continued The SNF will still be required to complete the 30-day assessment within days 27-33 The 30-Day assessment would cover Days 31 through 60 if Medicare eligibility requirements continued to be met The 14-Day assessment is required to be completed, but will not be used for payment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 57
  • 58. Late PPS Assessment Example # 2: A 30-Day assessment is completed with an ARD of Day 30 Day 7 of the COT observation period = Day 37…but the COT assessment is not done An EOT OMRA is performed timely with an ARD of day 42 (last rehab treatment provided on day 39) On Day 52 the facility determines that a COT should have been completed with an ARD of day 37…the COT is now a late assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 58
  • 59. Late PPS Assessment Example #2 (Continued) The ARD for the (late) COT is set for day 52…the day the error was discovered The late COT would have controlled payment from day 31 until the next assessment used for payment, had it been timely The EOT OMRA is an intervening assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 59
  • 60. Late PPS Assessment Example #2 (Cont.) The facility will bill default for 9 days (period COT would have controlled) The facility will bill the HIPPS code from the EOT OMRA as per normal, beginning the first non-therapy day, until the next scheduled or unscheduled assessment used for payment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 60
  • 61. Missed PPS Assessment If the SNF fails to set the ARD of a scheduled PPS assessment prior to the end of the last day of the ARD window and the resident was already discharged from Medicare Part A when the error is discovered the provider cannot complete and assessment and the days cannot be billed to Medicare A Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 61
  • 62. Missed PPS Assessment In some cases, an existing OBRA assessment (except a stand-alone discharge assessment) in the QIES ASAP system may be used to bill for some Part A days when specific circumstances are met See RAI User’s Manual pages 6-54 & 55 (Version 1.11, October 2013) Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 62
  • 63. Missed PPS Assessment In the case of an unscheduled PPS assessment if the SNF fails to set the ARD for an unscheduled PPS assessment within the defined ARD window and the resident is discharged from Part A the assessment is missed and cannot be completed All days are provider-liable Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 63
  • 64. Missed PPS Assessment A missed unscheduled PPS assessment will have all days paid at provider- liable until an intervening assessment controls the payment The intervening assessment will control payment until another assessment payment block begins Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 64
  • 65. 65 Harmony Healthcare International, Inc. OMRAs: Setting the ARD For the Change of Therapy (COT) OMRA, End of Therapy (EOT) OMRA, and Start of Therapy (SOT) OMRA, the decision for which day within the allowable ARD window the ARD of the assessment will be set may be made up to two days after the window has passed These are not additional grace days that may be chosen as the ARD These are additional days to “open” the MDS Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc.
  • 66. Harmony Healthcare International, Inc. 66 Completing Resident Interviews on Stand-alone OMRAs Providers are encouraged to complete resident interviews in as timely a manner and as complete as possible Interviews for OMRAs may occur one to two days after the ARD CMS expects most OMRAs will not catch providers by surprise Copyright © 2013 All Rights Reserved
  • 67. Interviews for Stand-Alone EOT, COT and SOT OMRAs On the day the interview would be conducted, the assessor may refer back to the previous scheduled or unscheduled assessment and determine if the date of the interview is within 14 days If the date noted is within 14 days of when this interview was to be done, the prior information may be used so long as the person who conducted the prior interview is available to sign the current assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 67
  • 68. Interviews for Stand-Alone EOT, COT and SOT OMRAs - Example 30-day assessment ARD was March 10 Interview date (as noted in Z0400) was March 8 COT observation period ends on March 17 If the team determines that a COT is required the interview from the 30 day may be carried forward to the unscheduled assessment ARD of COT and the date the interviews would be conducted = March 17 Date in Z0400 = March 8 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 68
  • 69. Interviews for Stand-Alone EOT, COT and SOT OMRAs - Example 30-day assessment ARD was March 10 Interview date (as noted in Z0400) was March 8 First COT observation period ends on March 17 – no COT required Next COT observation period ends on March 24 – team determined that the COT was required Interviews form the 30 day may not be carried forward from the prior assessment Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 69
  • 70. Interviews for Stand-Alone EOT, COT and SOT OMRAs Key points: The person who conducted the original interview must be available to sign the current assessment in Z0400 The date of the original interview will be put in Z0400 of the current assessment The clinical status of the resident must not have changed This only applies to resident interviews, not staff assessments Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 70
  • 71. Medical Leave of Absence (MLOA) For scheduled PPS assessments the Medicare assessment schedule is adjusted to exclude the LOA when determining the appropriate ARD for an assessment For unscheduled PPS assessments the ARD of the assessment is not adjusted for an LOA, because ARDs for unscheduled assessments are not tied to any particular Medicare day Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 71
  • 72. Harmony Healthcare International, Inc. 72 Medical Leave of Absence (MLOA) If a resident is out of the facility over a midnight, but for less than 24 hours, and is not admitted, the Medicare assessment schedule is not restarted However, there are payment implications: the day preceding the midnight on which the resident was absent from the nursing home is not a covered Part A day Becomes Medicare “skip day” Copyright © 2013 All Rights Reserved
  • 73. Harmony Healthcare International, Inc. 73 Resident Discharged On or Before Eighth Day of SNF Stay If the beneficiary dies, is discharged from the SNF, or discharged from Part A level of care before the eighth day of covered SNF stay, the resident may be a candidate for the Short- Stay Policy The Short-Stay Policy allows the assignment into a Rehabilitation Plus Extensive Services or Rehabilitation category when a resident was not able to receive 5 days of therapy Copyright © 2013 All Rights Reserved
  • 74. Medicare Short-Stay Assessment 1. The assessment must be a Start of Therapy OMRA A0310C = 1 or 3 2. A PPS 5-day or re-admission return assessment must be complete (may be combined) 3. The ARD (A2300) must be on or before the 8th day of the Part A Medicare covered stay The ARD minus the start of Medicare stay date (A2400B) must be 7 days or less Harmony Healthcare International, Inc. 74Copyright © 2013 All Rights Reserved
  • 75. Harmony Healthcare International, Inc. 75 Medicare Short-Stay Assessment 4. The ARD (A2300) of the Start of Therapy OMRA must be the last covered Medicare Part A day. The Start of Therapy OMRA ARD must equal the end of Medicare stay date (A2400C). The end of the Medicare stay date is the date Part A ended **See instructions for A2400C in Chapter 3 for more detail Copyright © 2013 All Rights Reserved
  • 76. Harmony Healthcare International, Inc. 76 Medicare Short-Stay Assessment 5. The ARD (A2300) of the Start of Therapy OMRA may not be more than 3 days after the start of therapy date not including the Start of Therapy date 6. Rehabilitation therapy (Speech-Language Pathology services, Occupational Therapy, or physical therapy) started during the last 4 days of the Medicare Part A covered stay (including weekends) Copyright © 2013 All Rights Reserved
  • 77. Medicare Short-Stay Assessment 7. At least one therapy discipline continued through the last day of the Medicare Part A covered stay 8. The RUG group assigned to the Start of Therapy OMRA must be Rehabilitation Plus Extensive Services or a Rehabilitation group (Z0100A) Harmony Healthcare International, Inc. 77Copyright © 2013 All Rights Reserved
  • 78. Harmony Healthcare International, Inc. 78 Medicare Short-Stay Assessment If all eight of these conditions are met, then the assignment of the RUG-IV rehabilitation therapy classification is calculated based on average daily minutes actually provided, and the resulting RUG-IV group is recorded in MDS item Z0100A (Medicare Part A HIPPS Code) Payment begins the date of the first therapy evaluation through date of discharge Use the Short Stay Algorithm Copyright © 2013 All Rights Reserved
  • 79. Harmony Healthcare International, Inc. 79 RUG-IV Rehab Categories Short-Stay Assessment 15-29 average daily therapy minutes = RL_ 30-64 average daily therapy minutes = RM_ 65-99 average daily therapy minutes = RH_ 100-143 average daily therapy minutes = RV_ =/> 144 average daily therapy minutes = RU_ Copyright © 2013 All Rights Reserved
  • 80. MDS Correction Process Considerations Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 80
  • 81. Harmony Healthcare International, Inc. 81 MDS Correction Errors that inaccurately reflect the resident’s clinical status and/or result in an inappropriate plan of care are considered significant errors (used to be called “major” errors) Correct via OBRA significant correction MDS Must also modify previous assessment while in process Most corrections are minor All other errors related to the coding of MDS items are considered minor errors Copyright © 2013 All Rights Reserved
  • 82. Harmony Healthcare International, Inc. 82 MDS Correction If an minor error is discovered in a record in that has been submitted, Modification or Inactivation procedures must be implemented by the provider for correction: Must be corrected within 14 days after identifying the errors Transcription errors, data entry errors, software product errors, or item coding errors can be modified Copyright © 2013 All Rights Reserved
  • 83. Harmony Healthcare International, Inc. 83 Modification A Modification request moves the inaccurate record into history in MDS database and replaces it with the corrected record as the active record Most MDS item errors can be corrected via modification process Modification does not require that a new assessment be completed Copyright © 2013 All Rights Reserved
  • 84. Harmony Healthcare International, Inc. 84 Modification Modification correction request is Section X: Item A0050, Type of Record, should have a value of 2 or 3, indicating a modification request (New for April 1st, 2012) 2 = Modify existing record 3 = Inactivate existing record Assessors must be sure to replicate the information exactly as it appeared on the erroneous record! Copyright © 2013 All Rights Reserved
  • 85. Harmony Healthcare International, Inc. 85 Inactivation An Inactivation request also moves the inaccurate record into history of the MDS database but does not replace it with a new record. Must send a new assessment to replace (if assessment was required) Records based on an event that did not occur (e.g., the record submitted does not correspond to any actual event) will not require a replacement For example, a discharge record was submitted for a resident but there was no actual discharge; thus, there was no event Copyright © 2013 All Rights Reserved
  • 86. Inactivation vs. Modification As of May 2013 providers may correct some fields via the modification process that were previously only able to be corrected via inactivation The ARD can be changed only when the ARD on the assessment represents a data entry/typographical error, and only if it does not result in a change in the look- back period that was considered while completing the assessment Harmony Healthcare International, Inc. 86Copyright © 2013 All Rights Reserved
  • 87. Inactivation vs. Modification The Type of Assessment items (A0310) can be modified if the Item Set Code (ISC) of that assessment does not change If the item subset would change, a modification cannot be done Full list of item subsets can be found in the RAI Users Manual, section 2.5 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 87
  • 88. Inactivation vs. Modification Type of Provider (A0200) cannot be modified Type of Provider (A0200) errors must be corrected via inactivation and submission of a new MDS assessment PPS stand alone assessments will only require modification, not inactivation PPS and OBRA combined assessments may require modification or inactivation Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 88
  • 89. Harmony Healthcare International, Inc. 89 MDS Correction Correction of these items requires a Special Manual Record correction: Submission Requirement (A0410) State-assigned facility submission ID (FAC_ID) Production/test code (PRODN_TEST_CD) The facility must submit a written request to the state MDS Coordinator to have the problems fixed Copyright © 2013 All Rights Reserved
  • 90. Final Thoughts… Proactive management of the PPS schedule is the key to successful management Daily communication between Therapy department and MDS department about potential for unscheduled assessments and ARD dates Use a 100 day tracker Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 90
  • 91. Final Thoughts… Strategic selection of ARDs and assessment types Careful monitoring of provision of Therapy minutes to ensure the patient is on track for the planned intensity Timely opening and completion of MDS assessments Up-to-date RAI User’s Manual and use your Harmony consultant as a resource Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 91
  • 92. References RAI Users Manual version 1.11 (October 2013) Medicare Claims Processing Manual Chapter 30 Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 92
  • 93. Questions/Answers Harmony Healthcare International 1 (800) 530 – 4413 Bdow@harmony-healthcare.com Harmony Healthcare International, Inc. 9393Copyright © 2013 All Rights Reserved
  • 94. Harmony Healthcare International Have you Considered a Customized Complimentary HARMONY(HHI) MEDICARE PROGRAM EVALUATION or CASE MIX ANALYSIS for your Facility? Perhaps your facility has potential for additional revenue Assess your facility against key indicators and national norms Email us at for more information RUGS@harmony-healthcare.com Analysis is cost & obligation free Harmony Healthcare International, Inc. 94Copyright © 2013 All Rights Reserved