The Long-Term Care Resident Assessment Instrument (RAI) 3.0 User’s Manual (RAI User’s Manual) version 1.20.1, effective Oct. 1, 2025, will bring major changes to section O of the MDS 3.0. The most significant update introduces item O0390, Therapy Services, replacing most of the current O0400 (Therapies) and removing O0420 (Distinct Calendar Days of Therapy) entirely. With this change, the Centers for Medicare & Medicaid Services (CMS) shifts from requiring detailed information on the volume of therapy, as well as start and end dates, to simply checking if the resident received the service. This article details three key takeaways to help nurse assessment coordinators (NACs) prepare for the new requirements.
Takeaway 1: O0390 is a new streamlined version of O0400
The new item, O0390, Therapy Services, consolidates much of O0400 into a new streamlined format. NACs will now indicate with a checkmark whether the resident received at least 15 minutes per day of a therapy discipline on one or more days in the 7-day look-back period. CMS eliminated the need to collect detailed information on how many days the individual, concurrent, group, and co-treatment therapy was provided. They also removed the coding of the start and end of therapy by discipline. Now, O0390 only identifies if services were provided in each of the disciplines: speech language pathology, occupational therapy, physical therapy, respiratory therapy, and psychological therapy. If the resident did not meet the threshold for any discipline during the observation period, “None of the above” is checked.
The updated RAI User’s Manual offers an example for this new item:
- Resident Z’s assessment has an ARD [assessment reference date] of 09/05/24. Review of the records shows Resident Z received occupational therapy on 08/30/24 for 25 minutes, 09/01/24 for 15 minutes, and 09/03/24 for 30 minutes.
- Coding: O0390B would be checked.
- Rationale: Resident Z received at least 15 minutes of occupational therapy on at least one day during the observation period.
Takeaway 2: One item remains in O0400, Therapies – Respiratory Therapy
CMS was unable to remove all of O0400 because of how the Patient-Driven Payment Model (PDPM) uses respiratory therapy. Respiratory therapy qualifies for the Special Care High clinical group of the Nursing component but only when the resident receives it for all seven days during the look-back period. Because this specific data point maps from O0400D, CMS maintained this one item in O0400 that collects the number of days respiratory therapy was administered for at least 15 minutes a day during the 7-day look-back period.
This item also has a new instruction that only needs to be completed if O0390D, Respiratory Therapy, is checked. The updated RAI User’s Manual also maintained the steps for assessment and coding instructions specifically for this item.
Takeaway 3: Supporting documentation for therapy must be reviewed
Even though O0390 streamlined the process of identifying if the resident received therapy, it did not remove the underlying considerations. The assessor must still confirm that the resident was provided with at least 15 minutes of skilled therapy before coding it for each discipline. The RAI User’s Manual kept most of the previous instructions from O0400 in O0390, detailing what constitutes a day of therapy, as well as what can and cannot be included in the minutes of skilled therapy.
The updated manual continues the instructions that only skilled therapy can be included in item O0390 and still details the therapy modes. Additionally, the instructions continue to state that therapy aides cannot deliver skilled services and that therapy students must be in the line of sight of the treating therapist. Although the MDS coding is simpler now, the underlying documentation to support the services remains at the same level: it requires the skills of a therapist and must occur for at least 15 minutes in one day.
Conclusion
The Oct. 1, 2025, changes to section O represent a shift toward streamlined reporting and away from minute-driven oversight. NACs and the interdisciplinary team should update policies, adjust workflows, and ensure therapy documentation is complete and accessible. The simplicity of O0390 coding does not negate the responsibility to report the delivery of therapy accurately. With preparation, training, and strong communication between therapy and nursing teams, facilities can meet these new requirements with confidence.
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