Home Health & Hospice Week

Should you bill with no assessment?

Although Medicare's therapy reassessment requirement went into effect back in April, many home health agencies have unresolved questions about the rule.

For example: "If the therapy reassessment was not completed timely and there are therapy services that were done, should these be billed even though they wouldn't be covered?" an HHA asked HHH Medicare Administrative Contractor NHIC.

The answer to that is "yes," NHIC says on its website in a question-and-answer set. "The home health claim should reflect all services that were provided to a patient during the home health episode. The therapy billed for the episode would then reflect covered and non-covered services," the MAC explains at www.medicarenhic.com/RHHI/ billing/J14%20HHH%20ACT8311QAs.pdf.

Another question: One MAC is telling agencies that "qualified therapist reassessments in a multiple therapy case must be 'AS CLOSE TO' the 13th and 19th visits as possible, implying no flexibility," the National Association for Home Care & Hospice notes in its member newsletter. But earlier guidance from the Centers for Medicare & Medi-caid Services indicated the requirement would be less rigid.

The reassessment doesn't have to be on the visit directly before the 13th or 19th visit, CMS confirms to NAHC. "Because we have not defined 'close to,' in the 13th/19th-visit regulations for patients receiving more than one type of therapy, the reassessment visits could be done by the therapist as you described (i.e., the visit before the closest visit)," CMS tells the trade group, according to NAHC. (For more advice on what constitutes "close to," see Eli's HCW, Vol. XX, No. 17, p. 131).