Home Health & Hospice Week

Start setting up your operations to make therapy reassessment windows.

New therapy assessment requirements have eased in the 2011 PPS final rule, but agencies still have a lot of new therapy hoops to jump through to secure payment.

In its July prospective payment system proposed rule, the Centers for Medicare & Medicaid Services floated the idea of requiring a functional therapy reassessment strictly on the 13th and 19th therapy visits. But in the final rule issued Nov. 2, CMS loosens up that timeframe. "We find compelling the commenters' concerns regarding scheduling difficulties," CMS says in the final rule.

CMS now will require HHAs to have therapy reassessments between the 11th and 13th therapy visit and between the 17th and 19th therapy visit, it says in the rule.

Clarification: "The policy applies to each discipline separately," CMS says in the rule. "The patient's function must be initially assessed and periodically reassessed by a qualified therapist of the corresponding discipline for the type of therapy being provided (that is, PT, OT, and/or SLP)."

For example: "If a patient has 12 physical therapy visits and 12 occupational therapy visits in an episode, the additional assessments would not be required," explains the National Association for Home Care & Hospice.

Watch for a possible changing interpretation of the single-discipline count, though, says Chicago-based regulatory consultant Rebecca Friedman Zuber. "That approach opens the door for unscrupulous agencies to throw in a few OT visits and reduce PT visits in order to avoid the assessment requirement, but still capture the revenue," Zuber tells Eli.

Timeline: HHAs have some extra time before the assessments become required. The new deadline for them is April 1, 2011.