PPS rule chock full of changes for HHAs. The U.S. Senate and the Securities and Exchange Commission aren't the only ones taking a close look at home health therapy. The Centers for Medicare & Medicaid Services proposes a whole new raft of documentation requirements for furnishing home health therapy, according to the prospective payment system proposed rule for 2011, published in the July 23 Federal Register. "CMS proposes to clarify policies regarding the coverage of therapy services in the home health setting," the agency notes in a release about the rule. Changes to slow therapy-driven case mix growth include "new functional assessment and reassessment requirements, therapy goal criteria, and clinical documentation requirements," notes the National Association for Home Care & Hospice. "In addition, timelines are offered for visits by a 'qualified therapist' (rather than therapy assistant) on the 13th and 19th visit and every 30 days." Other provisions in the 2011 proposed PPS rule address: • CHOWs. CMS revises rules put in place this year for changes of ownership within 36 months of a start-up or sale. The new provisions ease some restrictions while expanding its scope in other areas, NAHC says. • Capitalization. CMS is revising its regulations to conform with its recent practice regarding capitalization. CMS requires "initial reserve operating funds" (IROF) for three months at application and "at all times during the enrollment process," CMS says. This means HHAs must prove they have the funds prior to receiving billing privileges. CMS can also revoke billing privileges if the HHA fails to meet the requirement within three months of receiving those privileges. • CAHPS. CMS expands on agency requirements to submit CAHPS data for full payment in 2012. Agencies must submit at least one month's worth of "dry run" data for July, August, or September, the agency reiterates. Note: Watch for more in-depth coverage of these PPS rule items in future issues of Eli's Home Care Week.