Home Health & Hospice Week

The face-to-face encounter requirement isn't the only new mandate that hit home health agencies April 1. Medicare's new therapy reassessment requirements also took effect on that date.

Under the requirement, therapists -- rather than therapy assistants -- must conduct functional reassessment visits on the 13th and 19th visits or every 30 days. CMS also now requires more specifics in therapists' documentation (see Eli's HCW, Vol. XX, No. 6, p. 42)

Many HHA managers attending the National Association for Home Care & Hospice's March on Washington conference expressed concern about getting the timing right for the reassessment visits.

Having multiple therapy disciplines involved in a case may make counting visits for reassessment visits harder, since HHAs must use the sum total of all therapy visits to determine reassessment timepoints. But one aspect of such cases is also easier -- CMS allows therapists to make the visits in the 11-to-13 and 17-to-19 ranges for "exceptional circumstances," such as when multiple disciplines are involved.

HHAs should err on the side of caution and send out therapists early in the range to avoid missing the reassessment window, suggested CMS's Lori Anderson in a March 28 session at the conference. Agencies will need to document the exceptional circumstances required to make use of the visit ranges, she added. CMS was intentionally "not prescriptive" about conditions that qualify for those exceptional circumstances.

Official manual guidance about the therapy requirements is still hung up in clearance, Anderson noted. But the content of the guidance is contained in CMS's recently released therapy fact sheet.

Remember: "Where more than one discipline of therapy is being provided, at least once every 30 days, a qualified therapist from each of the disciplines must provide the ordered therapy service, functionally reassess the patient, and compare the resultant measurement to prior assessment measurements," CMS explains in the fact sheet. "The therapist must document in the clinical record the measurement results along with the therapist's determination of the effectiveness of therapy, or lack thereof."

The requirement shouldn't lead to duplication, CMS maintains. "In multi-discipline therapy cases, the qualified therapist would reassess functional items (and measure and document) those which correspond to the therapist's discipline and care plan goals."

How to count: "In cases where more than one discipline of therapy is being provided, the 30- day clock begins with the first therapy service (of that discipline) and the clock resets with each therapist's visit/assessment/measurement/documentation (of that discipline)," CMS says. If therapy reaches 13 or 19 visits, therapists must reassess based on the therapy visit total across all types of therapy.

CMS didn't limit therapists to certain tools for the objective measurements, notes the American Speech-Language-Hearing Association on its website. CMS told the therapy trade group that emphasis should be placed on the concepts of "measurable" and "objective," rather than limiting clinicians to a list of approved tests, ASHA says.

Note: The therapy fact sheet is at www.cms.gov/HomeHealthPPS/Downloads/Therapy_Requirements_Fact_Sheet.pdf.