The Medicare Home Health Proposed Rule was release last week. Among proposed payment changes, Face to Face clarifications, and new sanctions for non-compliance with federal requirements, the Therapy Assessment Rule is also slated for changes and improvements. But are all of these proposed changes really improvements to this Therapy Rule?
Clearly an improvement to the rule—CMS proposes to revise the regulations to state that if a qualified therapist missed a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, not the visit after the therapist completed late reassessment.— Currently, when a qualified therapist misses one of the required reassessment visits, once the therapist has completed the required reassessment, coverage resumes after this reassessment visit.
In addition, CMS proposes to revise the regulations to state that” in cases where multiple therapy disciplines are involved, if the required reassessment visit was missed for any one of the therapy disciplines for which therapy services were being provided, therapy coverage would cease only for that particular therapy discipline”. Therefore, as long as the required therapy reassessments were completed timely for the remaining therapy disciplines, therapy services would continue to be covered for those therapy disciplines. Again this change appears to work in favor of the provider. — Currently the regulation states, even if qualified therapists from the other therapy disciplines have completed all their required reassessment visits, therapy visits for these disciplines would not be covered until the qualified therapist who missed the reassessment visit has completed the previously missed reassessment visit.
This last change has potential to cause headaches for scheduling the multi-therapy visits. —CMS is proposing a change to allow “flexibility” and guidance to the provider. This change would be applicable in cases where beneficiaries are receiving more than one type of therapy; the qualified therapists could complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th visit for the required 19th visit reassessment. — Currently the regulation states that therapist’s visit need only be “close to” the 13th and 19th visits. This proposed revision does not appear flexible but rather has great potential for scheduling patients’ visits for three disciplines to be extremely inflexible. Hopefully stakeholders will comment on this proposed change.