Home Health & Hospice Week

Do you know when to require your therapists to conduct reassessments under the new rule that took effect this year? If you interpret the requirement too tightly, you'll decrease your productivity and increase your scheduling hassles for no reason. And if you interpret it too loosely, you're risking your reimbursement and your compliance record.

Home health agencies continue to be confused about the timeframes for the therapy reassessments that were required as of April 1, said a Centers for Medicare & Medicaid Services official in the Aug. 17 home health Open Door Forum. A provision meant to give HHAs more flexibility with timing of the reassessments is a main culprit, said CMS's Lori Anderson.

Under last year's final prospective payment system rule, HHAs can use a relaxed timeframe for conducting therapy reassessments for patients receiving therapy from multiple disciplines. Under the rule, the reassessment must occur "close to" and before the 14- and 20-visit mark, in the aggregate.

CMS didn't say "it has to be between this visit and that visit," Anderson pointed out. Just "close to" the threshold visits. (For analysis on what counts as "close to," see Eli's HCW, Vol. XX, No. 17, p. 131.)

For single-therapy-discipline episodes, therapists must conduct the reassessment exactly on the 13th and 19th visit. In rural areas or for "documented circumstances outside the control of the therapist," therapists can make the reassessment in the 11-13 or 17-19 visit range, CMS says in the 2011 PPS final rule.

Other HHA issues addressed in the forum include:

• 2012 PPS proposed rule. Don't forget to submit your comments on the PPS proposed rule, urged CMS's Randy Throndset in the forum. The rule published in the July 5 Federal Register includes a 3 percent payment cut due in part to so-called case mix creep, therapy reimbursement changes, and case mix and face-to-face changes. Comments are due Sept. 6.

• Illegal aliens. If you've been providing services to an illegal alien, you will be out your Medicare reimbursement with no recourse. That's what happened to one CareSouth agency, said the HHA's Tina Coleman in the forum. The agency's RAP rejected with a message that the patient was unlawfully in the country, even though the patient had a seemingly valid Medicare number, Coleman related.

CMS's Wil Gehne said he would research the issue to see if there's any way to prevent the problem. Other HHAs are seeing this problem as well, commented Mary St. Pierre of the National Association for Home Care & Hospice.