With all the snow and treacherous weather hitting the northern (and some southern) states, knowing the rules surrounding the unscheduled RUG assessments is key to maintaining your revenue. Most of the unscheduled assessments are self-explanatory, however the Chang of Therapy (COT) assessment can wreak havoc in your MDS department when bad weather strikes.
As you know, you must have therapists on-site in order to provide the therapy days and minutes which helps drive the RUG scores. When bad weather strikes, not having a therapist or two can significantly impact your RUG scores, and consequently, your reimbursement. The current regulations regarding the COT means that we are essentially assessing patients every seven days and potentially changing payment for the seven days prior to the COT assessment.
All of the Rehab RUGs (except Rehab Low) require a patient to be seen for five days in the look-back period. That, coupled with the minute requirements means that during inclement weather where employees might not make it to work your revenue can be significantly impacted. If, on the Assessment Reference Date (ARD) for the COT, you do not have enough minutes to keep the patient in the current RUG category, you MUST do a COT assessment to change the RUG for the previous seven days. This may mean that the patient drops a RUG category or two at least until the next COT or scheduled assessment. This issue is fairly easy to overcome and minimize.
Inclement Weather Can Threaten SNF Revenue – Big Picture
The bigger issue here is providing at least five days of therapy in the look-back period. Even if you have the minutes of therapy, if you do not have the minimum number of days in the look-back then you have not achieved the Rehab RUG. In the current world of Unique Therapy Days, all Rehab RUGs require five unique days of therapy (except for Rehab Low) in order to achieve that RUG. There are two discipline requirements for Rehab Ultra High and all have minute requirements.
If you do not achieve the Rehab RUG at the COT checkpoint then that patient will now be in a Nursing RUG for that seven day look-back period. You might think, “No big deal. We will just do another COT at the next checkpoint and change our RUG back to a Rehab RUG.” This would be incorrect. Under current regulation there is no mechanism in place to change a RUG for a patient who is receiving therapy from a Nursing RUG back to a Rehab RUG. Your only option at this point is to do a Significant Change Assessment (if you meet the Significant Change requirements) or wait until the next scheduled assessment which could be some time away. By virtue of the patient “falling” out of a Rehab RUG and into a Nursing RUG, the COT count stops. This is different than if the patient index-maximizes into a Nursing RUG. In the situation where the patient is receiving therapy and meets the Rehab RUG criteria, but because of the index-maximizing system, the Grouper software puts the patient into a Nursing RUG, then the COT count would continue and you may be able to get that patient back into a Rehab RUG at the next COT checkpoint.
As you can see, inclement weather can threaten SNF revenue, and bad weather and COTs do not mix well. However when bad weather is on the horizon some proactive, strategic planning could save you tens of thousands, if not hundreds of thousands of dollars in decreased reimbursement.