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I think you will end up in trouble if you try and
consider this resident skilled beyond 01/22 (01/12 + 10 days). Whether you
have a D/C order or not, you have documentation that states the services
were not provided after 1/12 and an OMRA should have been done within 10
days (assuming there are other reasons to skill the resident. Section P is
days and minutes of therapy provided, not ordered. With an ARD of 2/17, section
P reads all zeros.
Trying to lay out the time table I get the
following
Day 21 - 34 (01/06 - 01/19) the 30 day assessment
was due.
Day 27 = 01/12 (Therapy stopped)
Day 31 = 01/15
Day 50 = 02/04
Day 50 - 64 (02/04 - 02/18) the 60 day is
due
Day 60 = 02/14
Day 63 - 02/17 (ARD for 60 day)
I don't think there is a good way out of this.
I am concerned about what was on the 30 day
assessment . What was the ARD for that one and were the minutes on that
assessment accurate? If not, you need to correct that assessment, and then
correct the billing which I assume has already been submitted.
If the resident can not be skilled for reasons
other than therapy, you need to correct your billing to show him going off
of Medicare on 01/12.
If the resident can be skilled based on non-therapy
reasons, one alternative (one which has been
discussed ad nauseum on the listserver and most people agree is not allowed),
would be to do an OMRA with an ARD of 02/22, an R2b of 03/16, and adjust
your billing based on that. If it were me, I would do that. Even if it is not
technically allowed, you are using it to correct an error and not to gain any
benefit from it. I know of no other way to enter data into the system that will
accurately reflect what happened.
Nathan
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