Q: Once the final rule goes into effect, will we need to do both an End of Therapy (EOT) OMRA and an End of Therapy – Resumption (EOT-R) OMRA?
A: According to the final rule, you have to complete an EOT OMRA when therapy services cease for three consecutive days, regardless of the reason. Then, if therapy resumes within 5 days after the last day of therapy at the same RUG-IV classification level, you have the option of completing an EOT-R OMRA. It is not mandatory, just an option. In situations where an EOT-R OMRA can be completed, the therapist would not need to conduct a new therapy evaluation or establish a new care plan, as the resident will be resuming therapy at the same level. However, if that level changes or the resident goes more than 5 days from the last day of therapy before resuming therapy services, the therapist would be required to conduct a new evaluation and establish a new care plan, also the facility could complete the optional SOT OMRA to ensure payment at the new RUG rate.
The EOT clarifications and EOT-R provision go into effect October 1, 2011.