Re: SNU/SNF 3-day rule

[Guest guest]

From my participation in one of the learning call/open forum in January 2011,

CMS interprets the " 3 days no therapy " and EOT OMRA requirement based on whether

your facility is a 5-, 6-, or 7-day therapy provider. It seems to me that CMS

takes this determination to the extreme: If your facility, within the past year,

has had 1 and/or 2 days weekend therapy coverage, then CMS sees your facility as

a 6- or 7-day therapy provider. That is, if your facility had Saturday coverage,

even not regularly, your facility is deemed as 6-day therapy provider. Same

thought goes to if your facility has had Saturday and Sunday therapy coverage

within the past year, not necessarily the same weekend, your facility will be

viewed as 7-day therapy provider. Scenario: therapy order is OT and PT 5x/week.

Prior to Monday, the resident received both OT and PT on last Friday. If for

some reason the resident did not receive any therapy on Monday, and therapy is

indeed necessary to continue 5x/week, an EOT OMRA ARD needs to be set on

Saturday, Sunday or Monday (day 1, 2, or 3). Therapy resumes on Tuesday, there

will be requirement to have new MD eval order, evaluation, care plan, etc. for

this new course of therapy/skilled Medicare A stay. The MDS calendar is not

reset to day 1, rather keep counting. It's just that on Saturday, Sunday, and

Monday the resident will become nursing RUG. And the new SOT OMRA ARD needs to

be the 5, 6, or 7th day using Tuesday as day 1.

Hopefully this helps. Any other view or information will be greatly appreciated.

Chung, MS, OTR/L

EHC Management LLC.

SNU/SNF 3-day rule

Hello Group,

Like others, we had heard in recent months that any 3-day lapse in

therapy in a skilled nursing setting (such as a holiday weekend)

requires an end-of-therapy OMRA and restart after the lapse. Now we're

hearing this is not yet a requirement, but rather, it is proposed for

2012. Can anyone tell me if Medicare currently requires an EOT OMRA for

any 3-day break in treatment, or is that something we can look forward

to in the future?

Thank you,

Christen, PT

Director of Rehabilitation and Occupational Health

FHN

Freeport, IL