Counting therapy visits for Medicare's new therapy reassessment requirement just got complicated again. Based on the language in the prospective payment system final rule, the National Association for Home Care & Hospice thought that therapists would have to reassess the patient only if their discipline's visits hit the 11 to 13-visit and 17 to 19-visit thresholds (see Eli's HCW, Vol. XIX, No. 39, p. 308). But that is not the case, CMS says in a clarification to the trade group. "Each discipline must document the findings of its assessment and progress toward the goals established to justify continued therapy for that discipline," CMS explains to NAHC. "Therefore, the 13th and 19th total therapy visits in an episode must be made by a qualified therapist who conducts a functional assessment and determines goal attainment." Each discipline: "The qualified therapist(s) for other therapy discipline(s) caring for the patient must visit and functionally assess the patient on the regularly scheduled visit(s) due to take place as near as possible, but prior to, the 13th and 19th total therapy visits," CMS reportedly tells NAHC.