Home Health & Hospice Week

Are you confused about when to have therapists conduct the new reassessment visits when multiple therapy disciplines are furnishing services? You're not alone.

That was a big area of confusion in the Centers for Medicare & Medicaid Services' proposed rule about the new therapy requirements, based on comments CMS received. In the 2011 PPS final rule published in the Nov. 17, 2010 Federal Register, CMS clarifies when agencies should have therapists conduct the reassessments.

Unfortunately, when multiple therapy disciplines are involved in an episode, a therapist from each discipline must conduct a reassessment, CMS spells out in the final rule. "The policy applies to each discipline separately," the agency explains.

"The patient's function must be initially assessed and periodically reassessed by a qualified therapist of the corresponding discipline for the type of therapy being provided (that is, PT, OT, and/or SLP)."

Visit timing: "When more than one therapy discipline is being provided, the corresponding qualified therapist would perform the reassessment during the regularly scheduled visit associated with that discipline which was scheduled to occur as near as possible to the 13th and 19th visit, but no later than the 13th and 19th visit," CMS elaborates.

Tip: You use the combined therapy count to add up the number of visits, the National Association for Home Care & Hospice explains in a question-and-answer set. Each type of therapist goes in for the reassessment at the visit closest to the total13th or 19th therapy visit without going over.

CMS doesn't have much patience with agencies that complain that it will be difficult to count the total therapy visits to know when the reassessment visits for each discipline are due. "HHAs must coordinate their patients' care per longstanding conditions of participation," CMS says in the rule. "We would expect such coordination to already be occurring."

Furthermore, "a small percentage of patients which receive 13 and 19 therapy visits receive more than 1 therapy discipline," CMS says. "Given the low volume of such patients and the added flexibility as described above, we do not believe that the coordination associated with multi-therapy discipline patients will be overly burdensome."

The added flexibility to which CMS refers is the change to allow the therapy reassessment visits to take place in the 11-13 and 17-19 visit ranges. But beware that those visit ranges only apply in certain circumstances.

The visit range applies only "when the patient resides in a rural area or documented circumstances outside the control of the therapist preclude the qualified therapist service at the 19th therapy visit," CMS says in the final rule.

The rural area will be defined by CBSA code, NAHC says in its Q&As.