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Ask the expert: COT

Q:  Regarding the COT count:  Is it correct that once a rehab RUG is no longer achieved that the 7 day COT count stops and does not begin again until 7 days following the next scheduled PPS Assessment. I was just told in a seminar on the new PPS Final Rule that the above is true, and that in the new OCT 2014 Final Rule this will be changed so that the COT count will not stop when a Rehab RUG is no longer achieved.

A: There is a lot more detail in the new Final Rule.

Original COT policy (Rehab category to changed Rehab category)

Complete a COT for patients classified into a RUG IV therapy category, if the total number of reimbursable therapy minutes delivered or other qualifiers (i.e., number of days, number of required therapy disciplines) changed to the degree that it would no longer reflect the RUG IV classification assigned.

FY 2012 SNF PPS Final Rule (adds Rehab category to Nursing category but still qualifies for Rehab category and back to any Rehab category)

This final rule extended the COT OMRA policy to apply to patients who were receiving a level of therapy sufficient for classification into a therapy RUG, but classified into a nursing RUG because of maximization (while receiving a level of therapy sufficient for classification onto a RUG-IV therapy category).

This policy change, however, eliminated the use of the COT for a small number of patients classified into a RUG IV but therapy services received during the COT observation window were not sufficient to qualify into any therapy classification, resulting in classification to a nursing category. Then during the subsequent week, when the therapy criteria are met again, the COT could not be used to reclassify them back into a Rehab category because it did not meet the exact qualifiers.  The only way for a patient to regain therapy status was to complete an end of therapy OMRA (EOT) and then a new Start of Therapy OMRA (SOT).

Revision to COT policy (adds Rehab category to Nursing category regardless of qualification into Rehab category but therapy is not discontinued and back to Rehab category)

This policy change proposes to use the COT process those patients who continued therapy during the COT observation period, but did not classify into any therapy category and then when therapy resumes use the COT to reclassify them back into the appropriate category.  This policy will not apply to situations where and EOT is performed because therapy ended during a COT window.

Several excellent examples are included in the FR to illustrate these points, one of which was corrected from the NPRM issued in May 2014.