Home Health & Hospice Week

Reader Question: How do I know when the new therapy reassessment visit is required? The final rule says at the 13th and 19th visits, but how do you count the visits?

Answer: Look no further than the "Therapy Requirements Fact Sheet" the Centers for Medicare & Medicaid Services recently posted to its website. "While changes to Publication 100-02, Chapter 7, Home Health Services are pending, the following information related to therapy requirements contained in the Calendar Year 2011 Final Home Health Rule is being provided to assist HHAs and therapists with these requirements that are effective April 1, 2011," the sheet says.

"Where more than one discipline of therapy is being provided, a qualified therapist from each of the disciplines must provide the ordered therapyservice and functionally reassess, measure, and document the effectiveness of therapy or lack thereof close to but no later than the 13th and 19th therapy visit," CMS says in the fact sheet. "The 13th and 19th therapy visit timepoints relate to the sum total of therapy visits from all therapy disciplines. In multi-discipline therapy cases, the qualified therapist would reassess functional items and measure those which correspond to the therapist's discipline and care plan goals."

In other words, you have to count all the therapy visits together for the 13- and 19-visit timepoints, even though each individual discipline must conduct a reassessment, CMS clarifies. This should resolve confusion on the timing issue, believes the National Association for Home Care & Hospice.

Watch out: Home health agencies that fail to have therapists conduct the necessary reassessments and related documentation will be furnishing non-covered care after those timepoints, CMS also makes clear in the sheet. CMS still needs to answer some vital reimbursement questions about this new therapy requirement, NAHC insists. For example, what happens when some of the disciplines complete the reassessment and others don't -- will their visits still be covered and paid? And will Medicare cover and pay for therapy reassessment visits furnished after the required timepoints?