Following the latest edition of the RAI Spotlight Newsletter (Volume 9, Issue 2) the DOH received requests for clarification regarding the use of a COT assessment for residents who are classified in a Nursing RUG due to Index maximization. The question on page 2 was: "The resident placed in a Nursing RUG on the 5-day, 14-day and 30-day assessment due to Index Maximization but was receiving therapy. Now on Day 37, therapy minutes have increased so she would place in a Rehab category. Can a COT be done?"

The answer is yes. John Kane, from CMS Division of Institutional Post-Acute Care, confirmed that a COT can be used in this instance. This response is based on the guidance on page 2-54 of the RAI User's Manual which states the following: "When the most recent assessment used for PPS, excluding an End of Therapy OMRA, has a sufficient level of rehabilitation therapy to qualify for an Ultra High, Very High, High, Medium, or Low Rehabilitation category (even if the final classification index maximizes to a group below Rehabilitation), then a change in the provision of therapy services is evaluated in successive 7-day Change of Therapy observation periods until a new assessment used for PPS occurs."

This question and answer is specific to the variable of index maximization. Please refer to the guidance on page 2-52 of the RAI User's manual regarding the use of a COT OMRA when a resident is not currently classified into a RUG-IV therapy group.