Recent changes to Medicare Part A mean skilled nursing facilities (SNFs) and their therapists must remain vigilant to make sure therapy services are provided consistently. The Centers for Medicare & Medicaid Services clarified an End of Therapy Other Medicaid Required Assessment (OMRA) must be completed for Medicare Part A patients who miss three consecutive days of therapy services, using an assessment reference date (ARD) of the first, second or third day after the last therapy treatment. The approaching holidays may create difficulties delivering therapy services on a regular schedule as therapy staff take time off or skilled residents spend extra time with family.

SNFs also are now required to perform an “informal assessment” every seven days to determine if the amount of therapy being delivered is consistent with the Resource Utilization Group (RUG) minutes on the last prospective payment system scheduled or unscheduled assessment. If the RUG group has changed, the facility must complete a Change of Therapy (COT) OMRA to adjust the reimbursement rate. Again, the upcoming holidays could impact levels of therapy delivered.

Providers should discuss staffing with their therapy provider prior to the holiday season to ensure staff will be available to accommodate resident needs. This may prevent headaches in the days and weeks to come. For more information, contact your BKD advisor or email Lori Brunholtz at lbrunholtz@bkd.com.