Time Coding

Q:  A therapy aide prepares a treatment space by gathering weights and adjusting equipment for 5 minutes, then spends 10 minutes transporting Mrs. Smith to the therapy area.  Mrs. Smith then receives 30 minutes of therapeutic exercise one on one from a physical therapist after which she joins a group of 3 other patients who all participate in an obstacle course together for 15 minutes.  How would these minutes be coded on the MDS?

A:  It would be coded as:

     35 minutes of individual PT
     15 minutes of group PT

The five minutes the aide spent setting up the treatment area for the individual treatment can be coded on the MDS.  Time the aide spent transporting the patient to and from the therapy area is not considered set up and cannot be counted (note- if the therapist did this and was able to complete some assessment of status, wc mobility or gait training along the way, it could be counted).  The exercise with the PT is considered individual treatment and the interaction with other patients in a shared activity is group.

Rehab RUG Determinations

Q:  If a Med A patient stays long enough for only 4 days of therapy, how can a Rehab RUG level be obtained since Section T projections have been eliminated from MDS 3.0?

A:  The Medicare Short Stay Assessment Indicator of a Start of Therapy (SOT) OMRA will average the provided therapy minutes to potentially determine a Rehab RUG level.   Six criteria must be met: 

1. SOT OMRA combined with any OBRA, PPS, SBCAA or discharge assessment
2. PPS 5-day or Readmission/Return has been completed/combined with SOT OMRA
3. ARD must be on or before Day 8
4. ARD must be on the last day of the Medicare Covered Stay
5. Rehab started (evaluation) within the last 4 days of the stay
6. At least one therapy discipline continued through the last covered day

If this criteria is met then the minutes of therapy provided is divided by the number of days from the therapy eval to the last covered day to obtain an average. Rehab RUG categories are assigned base on this average. Achieving varying RUG levels would require the following number of minutes per category:

• Ultra High= 144 minutes or above
• Very High= 100 to 143 minutes
• High= 65 to 99 minutes
• Med= 30 to 64 minutes
• Low= 15 to 29 minutes

Concurrent Therapy Considerations

Q:  How does CMS define “concurrent” therapy treatments and what is the impact of providing treatments with this mode? 


A:  For Medicare Part A, concurrent treatments occur when two patients are being treated at the same time by the same therapist/assistant yet they are not performing the same or similar activities.  Both patients must be in the line of site of the therapist/assistant.  Medicare Part B does not recognize concurrent therapy and anytime two patients are seen at the same time, the treatment must be billed and documented as a group treatment.  For Medicare Part A patients only ½ of the therapy minutes delivered concurrently will contribute for the total needed to achieve each Rehab Rug level.  Facilities with rehab programs utilizing a significant amount of concurrent therapy treatments may see lower RUG levels if additional treatment minutes are not provided by either individual or group therapy modes. An increased number of therapists or increased productivity of existing staff may need to be considered. 

MDS 3.0 Rehab-related Changes

MDS 3.0 brings many changes to our facility including some that specifically impact the rehab department and your financial viability.  Some key rehab related changes include:

• The elimination of Section T to project patients into the Medium or High Category even when the required minutes/days for those categories weren’t provided during the assessment reference period.
•  The treatment minutes delivered to a patient concurrently with another patient’s treatment are divided in half by the MDS 3.0 Grouper to determine the total for the RUG level.
•  An End of Therapy OMRA must be done 1-3 days after therapy discharge instead of 8-10 days.
•  A Start of Therapy OMRA can now be done to determine a Rehab RUG category before the next regularly scheduled assessment.
• A Medicare Short Stay Assessment may be done to capture a Rehab RUG level if the patient discharges on or before day 8.
• Treatment minutes completed by therapy aides or techs cannot be counted on the MDS but the time they spend setting up a treatment can.
• Treatment minutes completed by students can only be counted if done in direct line of site of a supervising therapist or assistant who is not treating another patient at the same time.