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Completing the SOT OMRA under the MDS 3.0

MDS 3.0 Update, August 9, 2010

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To prevent inappropriate RUG classification due to therapy projection, CMS decided to omit Section T from the MDS 3.0. Instead, facilities will use the optional Start of Therapy (SOT) Other Medicare-Required Assessment (OMRA), End of Therapy (EOT) OMRA, and Medicare Short-Stay Assessment to place residents in RUG categories based on the therapy services provided.

The SOT OMRA is an optional assessment designed to capture therapy services that start between regularly scheduled assessments. It can also be used to capture therapy services that start during the regular assessment window but are not substantive enough to get a rehab RUG from that assessment.

“Let’s say you have a resident who is on Medicare Part A because of skilled nursing but, six weeks into the stay, his weight-bearing status changes and he begins therapy. Under the MDS 2.0, you have to wait for the 60-day MDS to capture that therapy, unless you could call it a significant change,” says Theresa Lang, vice president of clinical services at Specialized Medical Services, Inc., in Milwaukee. “Under the MDS 3.0, you will be able to capture therapy when it starts with the SOT OMRA.”

The SOT OMRA is an abbreviated assessment that includes only the items necessary to place a resident into the appropriate rehab RUG. The assessment reference date (ARD) must be day five, six, or seven after the start of therapy. The date of the earliest therapy evaluation is counted as day one when determining the ARD, regardless of whether treatment was provided on that day. Payment for the rehab RUG determined by this assessment will begin on the first day therapy was provided.

Despite some concerns that the SOT OMRA will force facilities to complete more assessments in a shorter amount of time, thus increasing the workload of SNF staff, CMS and many industry experts do not see this assessment as a burden to facilities.

“Not only is the SOT OMRA much shorter than regular assessments, but it’s optional,” Lang says. “The only time a SOT OMRA will be accepted into the database is if it moves the resident into a rehab RUG. But even then, you don’t have to complete one if you don’t want to.”

This is an excerpt from the August issue of PPS Alert for Long-Term Care.

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