Following a very confusing Centers for Medicare and Medicaid Services (CMS) conference call in November, CMS has released a question and answer document intended to provide clarification in a number of Minimum Data Set (MDS) related areas.

Specifically, the document addresses the following topics:

• Clarification regarding use of the term “day of discharge”

• Clarification regarding early assessment penalty policy

• Clarification regarding the relationship between the change of therapy other Medicare required assessment (OMRA) and the day of discharge

• Clarification regarding the beginning of a change of therapy (COT) observation period

• Clarification regarding completion of interview items on a COT OMRA

• Clarification regarding when a COT evaluation should be completed

• Clarification regarding requirements for completing an end of therapy (EOT) OMRA

• Clarification regarding the relationship between the end of therapy OMRA and the day of discharge

• Clarification regarding how to bill an end of therapy OMRA reporting resumption

• Clarification regarding the definition of a resumption of therapy

• Clarification regarding a change in activities of daily living (ADLs) related to a resumption of therapy (EOT-R)

Nursing facility MDS coordinators, therapists, and billing staff should review the document to better understand CMS expectations. The document is available for review on the CMS website here.

Doug Beardsley
952.851.2489
dbeardsl@careproviders.org

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