Therapy Changes Clarified in PPS Rule

As part of the Home Health PPS Update for Calendar year 2012, CMS also made some minor technical changes to the therapy assessment language found in the prior PPS update for 2011.

Currently the regulation reads that the qualified therapist from each discipline must provide the therapy service and functionally reassess the patient…during the visit which would occur close to but before the 19th visit per the plan of care.  The regulation will now read “…during the visit which would occur close to but no later than the 19th visit per the plan of care.

Additionally, CMS clarified when occupational therapy is considered a “dependent” service and when it is considered a “qualifying” service.

It is a dependent service when the beneficiary initially qualifies for the home health benefit beginning the first episode of care.  That is, the beneficiary’s eligibility for the home health benefit is established by virtue of a need for intermittent skilled nursing, speech language pathology or physical therapy. Then they are entitled to SN, PT, ST, HHA, MSW and OT.

When occupational therapy is the sole skilled service being provided in subsequent episodes after the benefit has been established it is considered a “qualifying service.”

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