Home Health & Hospice Week

Making sure you hit your deadlines for the new therapy reassessment requirement is hard enough -- don't make it harder by mixing up your counting timelines.

Background: Under new requirements that took effect April 1, therapists (not therapy assistants) must complete reassessment visits both every 30 days and on the 13th and 19th visits, the Centers for Medicare & Medicaid Services said in the 2011 prospective payment system final rule. Under certain exceptions, therapists can provide the visits in the 11-13 and 17-19 visit ranges, or on visits "close to" the 13th or 19th visit (see Eli's HCW, Vol. XX, No. 16, p. 122).

This new requirement is giving therapists and home health agencies big headaches. "Therapists have become very frustrated with the amount of calling, scheduling, rescheduling, canceling, holding of a discipline while waiting on a reassessment, etc.," related to this requirement, reports occupational therapist Sarah Gassman Schultz, director of home health for PHC Home Health in Charleston, S.C. "They feel so much time is being spent on something that has nothing to do with the actual patient care and well-being of the patient, and in some cases is almost harming the patient," Gassman Schultz tells Eli.

The problem: Some home health agencies are exacerbating the problem by mixing up the requirements for the 30-day versus 13- and 19-visit reassessments, reports therapist and consultant Cindy Krafft with Fazzi Associates. This requirement is already so challenging, "why make it even harder?" Krafft asks.

The Medicare manual instructions issued last month make clear that therapists must make the 13- and 19-visit reassessments on the visit exactly, unless they qualify for one of the exceptions that allow a range or "close to" timeframe. But the 30-day timeframe visit can happen any time within that 30 days, from the beginning to the end of the episode, Krafft emphasizes.

The solution: Smart agencies will coordinate the 13- and 19-visit time point reassessments with the 30-day ones so that they don't have to send out a therapist for an extra visit at the end of the 30 days, Krafft says.

For example: Say a patient's 13th visit occurs on day 19 of a patient's second 30-day time period. The reassessment by the therapist on visit #13 can count as the reassessment visit for both the 13-visit timeframe and the 30-day timeframe. The 30-day visit does not have to take place at the end of the window, Krafft stresses.

From the horse's mouth: Remember that the 13- and 19-visit deadlines start over with every episode, but the 30-day deadline spans episodes, said CMS's Lori Anderson in the April Open Door Forum for home care providers. With the 30-day limit, "the start of the clock is always when the therapy from that discipline is provided," Anderson explained. "So the clock is reset every time the qualified therapist would perform that service."

Tip: HHAs may get better at counting the two types of therapy reassessment deadlines if they think of the 13- and 19-visit deadline as counting visits, and the 30-day deadline as "tracking" the requirement, Krafft recommends. "If they can separate that out, it becomes clear ... that the visits restart," she says.

Don't forget that the tracking piece is also specific to each discipline, and it crosses certs, Krafft says.

HHAs and therapists are likely confusing these two deadlines for a few reasons, Krafft believes. One is that CMS didn't issue the official manual instructions until more than two weeks after the requirement took effect. Another is that HHAs have been very consumed with face-to-face encounter requirements that hit at the same time.

Yet another reason for confusion is that some agencies and therapists assumed their software would just count the visits for them, Krafft says. But if your computer system alerts you to the 30-day deadline only at the end of the time period, you'll miss out on a chance to easily coordinate the 13- and 19-visit and 30-day on the same visit earlier in the episode, rather than sending out the therapist for an unnecessary visit at the end of the 30-day period.