Home Health & Hospice Week

Patients Over Paperwork-related change on deck.

Many home health agencies are making serious changes to the role of therapy in their organi­zations under the Patient-Driven Groupings Model, and a new proposal may increase that.

“In response to public feedback that we received under our Patient Over Paperwork Initiative, [the Centers for Medicare & Medicaid Services] is proposing to allow therapist assistants to perform maintenance therapy (rather than only therapists), which would allow them to practice at the top of their state licensure, give flexibility to home health providers, and improve beneficiary access to these services,” CMS says in a release about its 2020 Home Health Prospective Payment System proposed rule.

“While Medicare allows for skilled maintenance therapy in a [Skilled Nursing Facility], HH, and other outpatient settings, the type of clinician that can provide the therapy services vary by setting,” CMS explains in the rule published in the July 18 Federal Register. “In some settings” — such as SNFs — “both the therapist and the therapist assistant can deliver the skilled maintenance therapy services,” the rule says. “In other settings” — like home health — “only the therapist can deliver the ... services.”

CMS believes “it would be appropriate” to allow assistants to perform the services under a maintenance program “established by a qualified therapist under the home health benefit, if acting within the therapy scope of practice defined by state licensure laws,” the rule allows.

Therapists would retain many responsi­bilities, including “the initial assessment; plan of care; maintenance program development and modifi­cations; and reassessment every 30 days, in addition to supervising the services provided by the therapist assistant,” CMS points out.

On one hand: “Home health agencies should be in favor of this change to give themselves more latitude in using therapy staff,” says Joe Osentoski with Quality in Real Time in Sterling Heights, Michigan. That’s particularly true “since there will most likely be significant dislocation of therapists under the Patient-Driven Groupings Model as agencies adjust to the new payment model and evaluate their therapy utilization,” Osentoski adds.

The proposal “is a great move and speaks to the fact that therapy is not going away in PDGM,” says PT Cindy Krafft with Kornetti & Krafft Health Care Solutions.

On the other hand: “Due to the different nature of what the therapist is providing in a maintenance plan relative to a restorative plan, and what should be a generally lower number of therapy visits, keeping these interventions to the qualified therapist seems prudent,” Osentoski judges.

And “there are risks from an operational perspective,” Krafft tells Eli.