TN-Care Centers Management, Consulting

With regard to the proposed addition of the Change of Therapy (COT) OMRA, I would like to comment that it appears on initial review of the proposed rule that the addition of this assessment to the already burdensome number of assessment required for PPS, i.e. the discharge assessment added with MDS 3.0, would add an additional undue burden to practitioners in the field. There is natural flexibility in the way that rehab RUG scores are generated and should be allowed to remain flexible. The way that the rule reads, if a resident achieves a certain RUG score on a particular assessment, then if that RUG score differs within 7 days of the ARD of the preceding PPS assessment to the degree that it would no longer reflect the RUG classification and payment assigned to the resident based on the most recent assessment used for Medicare payment, and a SCOS is not appropriate, a COT would be required. While a full 7 days is usually necessary in order to achieve the 5 days necessary for classification into a rehab RUG, the requirement that the COT ARD be set on day 7 seems arbitrary. Changes occur daily, especially at the beginning and end of a SNF stay. The proposed rule does not specify whether this new RUG would indicate an improvement or a decline. In either case, it would seem possible that a COT could be required every 7 days. The proposed rule also does not indicate whether a COT could replace or be combined with a scheduled PPS assessment. And, it is not clear in the proposed rule whether, if a COT is completed in relative close proximity to a scheduled PPS assessment, i.e. a few days before the next assessment window opens, how often they would need to be completed. With the shortened assessment windows proposed in this rule, this could add significantly to the number of required assessments. Finally, the COT represents an additional management burden in that it will require additional time and resources to monitor and schedule.