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MDS Changes: Scheduler, ARD Tool, Timelines and Penalties

MDS Changes: Scheduler, ARD Tool, Timelines and Penalties. By : Dennis Artieda and Ruth Oglesby. Objectives. The participant will be able to : A. Determine the types of assessments B. Determine when to combine scheduled and unscheduled assessments

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MDS Changes: Scheduler, ARD Tool, Timelines and Penalties

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  1. MDS Changes: Scheduler, ARD Tool,Timelines and Penalties By : Dennis Artieda and Ruth Oglesby

  2. Objectives The participant will be able to : A. Determine the types of assessments B. Determine when to combine scheduled and unscheduled assessments C. Familiarize how to effectively use the MDS Scheduler and ARD Tool D. Identify the penalties imposed when assessments are completed untimely

  3. Overview • OBRA- Required Tracking Records and Assessments • Medicare- Required PPS Assessments • Assessments Combinations

  4. OBRA-Required Tracking Records and Assessments • Tracking Records • and Discharge Assessments • A. Entry • B. Death in Facility • C. Discharge ( return anticipated or return not anticipated)

  5. OBRA-Required Tracking Records and Assessments • Assessments: • 01- Admission • 02- Quarterly • 03- Annual • 04 - SCSA ( Significant Change of Status • 05- Significant Correction-Comprehensive • 06- Significant Correction- Quarterly • 99- Not OBRA

  6. Scheduled PPS Assessment 01 = 5 day 02 = 14 day 03 = 30 day 04 = 60 day 05 = 90 day 06 = Readmission/return 07 = Unscheduled assessment used for PPS (OMRA, Sig Change or Sig Correction) 99. Not PPS

  7. Unscheduled PPS Assessment-OMRA • OMRA (Other Medicare Required Assessment) • 0 - Not an OMRA • 1 - Start of Therapy (SOT) • 2 - End of Therapy (EOT) • 3 - Start/End of Therapy (SOT/EOT) • 4 -Change of Therapy (COT)

  8. Unscheduled PPS Assessment- EOT OMRA • Required in two different types of situation: • Therapy is discontinued, Part A continues • EOT-OMRA always is required under the following circumstances: • The Medicare Beneficiary is in a therapy RUG, and • All therapy is being discontinued , and • The resident will continue on Part A for skilled nursing care for at least three days. • 2. Temporary Cessation of Therapy

  9. Unscheduled PPS Assessment- EOT OMRA • It does not matter if the missed days are weekday, weekend or holiday • ARD must be set on days 1-3 after the last day of therapy was provided • The EOT OMRA will produce a non-therapy RUG

  10. Unscheduled PPS Assessment- EOT R • If therapy resumes within 5 calendar days, and • Therapy resumes at exactly the same level (number of services, number of days & minutes) • EOT-Resumption option can be selected O0450

  11. Unscheduled PPS Assessment- EOT R • Pays • 6/27-7/1 LB1 • 7/2- 7/30 RMB • Probably will need COT • EOT combined with 30 day and EOT-R • ARD day 29 (6/29) • EOT day 27 (6/27), EOT-R day 32 (7/2) • Z0100A-RMB, Z0150A-LB1 • Prior Assessment Z0100A RHA

  12. Unscheduled PPS Assessment- SOT OMRA • Optional Assessment • Completed to obtain a therapy RUG only when resident is not already in a Rehab or a Rehab + Extensive group • If the RUG is not one of these two, the SOT assessment will be rejected.

  13. Unscheduled PPS Assessment- SOT OMRA • Starts payment on the date of the first therapy eval and continues until the next PPS assessment • ARD must be 5-7 days after start of any therapy • Earliest tx. evaluation is counted as day #1 when setting the ARD. Medicare payment starts on first day of therapy

  14. ASSESSMENT COMBINATIONS • MEDICARE SHORT STAY – FOR STAY LESS THAN 8 DAYS • All eight must be true: • Must be a SOT OMRA • 5-day or readmission/return & may be combined with SOT • ARD must be Day 8 or earlier of the Part A stay • ARD must be the last day of Part A stay( A2400C algorithm on page A-28) • ARD cannot be more than 3 days after the SOT • Rehab must have started in last 4 days of Part A stay • Rehab must continue thru last day of Part A stay • RUG must classify into a Rehab + Extensive Service or a Rehab group RUG

  15. Unscheduled PPS Assessment- COT OMRA • ARD is Day 7 of the COT observation period • COT observation period is a successive 7-day window that begins the day after the ARD of the last PPS assessment used for payment unless the last assessment was an EOT-R, then the COT observation period starts on the resumption date

  16. Unscheduled PPS Assessment- COT OMRA • This is an informal process to determine if therapy RUG changed over the 7 day observation period • If the RUG used for billing changed due to any changes in therapy (minutes, days or number of disciplines) a COT is required – no change required only for ADL status change • Modifies the payment rate starting on Day 1 of that COT observation period

  17. Unscheduled PPS Assessment- COT OMRA • When is it required? • Last assessment has enough therapy for a Rehab group even if it did not score Rehab • Must check every 7 days after ARD (+7) or after EOT-R (+6) • If therapy RUG level would change (L,M,H,V,U) and either the original or current assessment has a Rehab RUG score • Not needed if another required assessment is done prior to COT date.

  18. Unscheduled PPS Assessment- COT OMRA • When is it required? • Change in Minutes will cause a change in the billed score • If index maximized to a non-rehab score and prior rehab was rehab-required • If index maximized to a rehab score and prior rehab was not rehab required • If both scores a rehab and not the same level required • If neither score is rehab-do not do the COT

  19. ASSESSMENT COMBINATIONS • Combining Medicare Scheduled and Unscheduled Assessments. • Combining Medicare Assessments and OBRA Assessments

  20. ASSESSMENT COMBINATIONS

  21. A. Combining Medicare Scheduled and Unscheduled Assessments

  22. Combining Medicare Scheduled and Unscheduled Assessments • If an unscheduled PPS assessment (OMRA, SCSA, SCPA is required in the assessment window (including grace days) of a scheduled PPS (PPS 5,14, 30, 60 & 90 day) assessment that has not yet been performed, then you must combine the scheduled and unscheduled by setting the ARD of the scheduled for the same day that the unscheduled is required. • See 2.10 on page Chapter 2-52 for all of the combinations

  23. Combining Medicare Scheduled and Unscheduled Assessments • If the ARD for an unscheduled PPS assessment falls within the ARD window ( including grace days) of a scheduled PPS assessment, and the ARD for the scheduled assessment would be set for a day after that of the unscheduled assessment, then the assessment must be combined. March 2012 RAI and MDS Conference

  24. Combining Medicare Scheduled and Unscheduled Assessments Example: PPS+ EOT OMRA If the ARD for an EOT OMRA is Day 14 of a resident’s stay and the 14-day scheduled PPS assessment is not set for prior to Day 14, then the assessments must be combined and facilities should use the appropriate AI code to indicate the combined assessment. March 2012 RAI and MDS Conference

  25. Combining Medicare Scheduled and Unscheduled Assessments COT and Other Assessments If the ARD of a PPS assessment used for payment for on or prior to Day 7 of the COT observation period, then no COT OMRA would be required. If an assessment has an ARD set for on or prior to Day 7of the COT observation period, but this assessment is not used for payment, then completing this assessment does not impact on the COT ARD calendar and the COT OMRA would still be required. March 2012 RAI and MDS Conference

  26. Combining Medicare Scheduled and Unscheduled Assessments The COT OMRA and Other Assessments If the ARD of a PPS assessment used for payment is set for on or prior to Day 7 of the COT observation period, then no COT OMRA would be required. March 2012 RAI and MDS Conference

  27. Combining Medicare Scheduled and Unscheduled Assessments The COT OMRA and Other Assessments Example: If the last day of the COT observation period is on May 4 and the ARD of the 30-day assessments is set for May 4, the SNF may choose not to complete the COT OMRA ( assuming the resident is not discharged prior to Day 32 of the stay) and the COT observation period would begin on May 5. March 2012 RAI and MDS Conference

  28. Combining Medicare Scheduled and Unscheduled Assessments The COT OMRA and Other Assessments Example: If the last day of the COT observation period is on May 4 and the ARD for an EOT OMRA is set for May 4, the SNF may choose not to complete the COT OMRA. If the ARD for the EOT OMRA were set for May 5, regardless of when therapy ended, then a COT OMRA would be required with an ARD of May 4. March 2012 RAI and MDS Conference

  29. Combining Medicare Scheduled and Unscheduled Assessments • COT OMRA and Other Assessments • Example: • 30 day done on day 27, COT would have been needed day 29 • Resident discharge day 30 (prior to the start of the reimbursement from the 30 day assessment) • A COT is still required and the 30 days assessment is ignored since it was not used for payment • Failure to do the COT on day 29 would be a missed assessment and provider liable. CMS recommends starting the book in such case then deleting it or not submitting it. March 2012 RAI and MDS Conference

  30. Combining Medicare Scheduled and Unscheduled Assessments WHAT HAPPENS IF I DO NOT COMBINE THE SCHEDULED AND UNSCHEDULED ASSESSMENT AS I SHOULD? If a scheduled assessment ARD is set for a day that is after the ARD set for an unscheduled assessment, and the ARD for the unscheduled assessment is set for a day within the scheduled assessment ARD window, then the scheduled assessment is not used for payment purposes. March 2012 RAI and MDS Conference

  31. ASSESSMENT COMBINATIONS WHAT HAPPENS IF I DO NOT COMBINE THE SCHEDULED AND UNSCHEDULED ASSESSMENT AS I SHOULD? Example: The COT OMRA completed with ARD of Day 13 and 14 day assessment ARD set for Day 15. The COT OMRA would pay beginning on Day 7 ( Day 1 of the COT observation period) through Day 15 and continue until the next scheduled or unscheduled assessment used for payment. Next COT observation period end date: Day 20 March 2012 RAI and MDS Conference

  32. ASSESSMENT COMBINATIONS WHAT HAPPENS IF I DO NOT COMBINE THE SCHEDULED AND UNSCHEDULED ASSESSMENT AS I SHOULD? Example: EOT OMRA completed with ARD of Day 14. Resident last received therapy on Day 11. The 14 day assessment ARD set for Day 15. The EOT OMRA would pay beginning on Day 12 through Day 15 and continue until the next scheduled or unscheduled assessment used for payment. March 2012 RAI and MDS Conference

  33. B. Combining Medicare Assessments and OBRA Assessments

  34. Questions?More Information? • ADLDATA.COM • Hotline@adldata.com • 9 Skyline Drive • Hawthorne, NY 10532 • (914) 591 1800

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