Home Health & Hospice Week

OTs achieve long sought after goal.

Medicare officials have knocked down another wall to optimal efficiency under COVID-19.

The Centers for Medicare & Medicaid Services “is waiving the requirements ... that rehabili­tation skilled professionals may only perform the initial and comprehensive assessment when only therapy services are ordered,” says a May 11 1135 waiver update. “This temporary blanket modification allows any rehabilitation professional (OT, PT, or SLP) to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether or not the service establishes eligibility for the patient to be receiving home care.”

Benefit: “Expanding [that] category of therapists ... provides HHAs with additional flexibility that may decrease patient wait times for the initiation of home health services,” CMS says.

CMS does include a few caveats, however. Therapists still “would not be permitted to perform assessments in nursing-only cases,” the waiver says.

And “we ... expect HHAs to match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible,” CMS says. Therapists also must act “within their state scope of practice laws” and “access a registered nurse or other professional to complete sections of the assessment that are beyond their scope of practice.”

“Therapy being able to admit even with nursing ordered creates a greater opportunity to manage clinical resources and allow agencies to decide which discipline is the best fit to complete the start of care,” cheers PT Cindy Krafft with Kornetti & Krafft Health Care Solutions.

This builds on another win for OT. Last month, CMS issued a waiver allowing “OTs to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether occupational therapy is the service that establishes eligibility” (see Eli’s HCW, Vol. XXIX, No. 14).

“OTs have been advocating to admit for 20-plus years, so it is a big win for them specif­ically,” Krafft says.

“Having OT open home health cases addresses the need for patients to receive the skilled occupational therapy they need, when they need it,” says the American Occupational Therapy Association in online analysis. “OT may be the most appropriate discipline to start a case, given that OTs assess and evaluate the patient’s home environment, evaluate functional status, identify possible safety issues, and identify other needs and strategies immediately,” the trade group says.

What’s in store? “Fingers crossed the demonstrable positive impact of these waivers move them to permanent changes,” Krafft tells Eli.

Pending legislation, the Medicare Home Health Flexibility Act (H.R. 3127/S. 1725), “would enable OTs to open Medicare home health therapy cases on a permanent basis,” AOTA notes.

CMS recently implemented regulations for another permanent home health change — nonphy­sician practitioners ordering home health services and certifying eligibility for HH. But that lasting change was specifically legislated in the CARES Act.

Note: The waiver summary document is at www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf.