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  • CMS Eases Reassessment Requirements in 2015 Home Health Rule

    Beginning in 2015, the Centers for Medicare and Medicaid Services (CMS) will adopt a change suggested by APTA and others, and replace a requirement that home health therapy reassessments be performed at the 13th and 19th visits with one that requires a reassessment every 30 calendar days by each therapy discipline. The new requirement is part of a set of finalized changes to the Home Health Prospective Payment System rule announced by CMS on October 30.

    Under the final rule, set to be implemented January 1, 2015, physical therapists (PTs) must "perform the needed therapy services, assess the patient, measure progress, and document objectives and goals at least once every 30 calendar days during the home health episode of care." The reassessment policy applies to physical therapy, occupational therapy, and speech-language pathology, and must be conducted by a qualified therapist from each discipline. In the case of physical therapy, "qualified therapists" would be limited to PTs.

    CMS had originally proposed that the reassessment be performed every 14 calendar days, but increased the requirement to 30 days after receiving comments from the public, including APTA.

    CMS also announced that it will eliminate the mandate for a "narrative" to be supplied by a physician in order to comply with a physician "face to face" requirement. APTA supported this change, expressing concerns that the current rule creates an undue burden on the home health community. The physician (or nonphysician practitioner) will still be required to certify that a face-to-face patient encounter occurred in order to meet the requirements for the home health stay. That encounter must take place no more than 90 days before the start of home health care or within 30 days after it begins.

    The final rule also includes 0.3% ($60 million) reduction for Medicare home health payments in 2015. This decrease is caused by a 2.1% increase to the home health market basket, which was then reduced by 2.4% for the second phase of home health rebasing. In addition, there are new provisions for the home health quality reporting program.

    The rule has been posted on the federal register. APTA will draft a complete summary of the final rule in the coming days, and will offer educational programs on this and other CMS rule changes for 2015.

    CMS will also be issuing rules for 2015 on the physician fee schedule and the outpatient prospective payment system. Visit APTA's PT in Motion News page to get the latest reports.

    Comments

    • I'm glad the rule for reassessments has changed. Although I understand the need for reassessments and would not mind continuing them at the half way mark, 13th RA, but it was ridiculous to have to perform another reassessment, 19th, within that time frame especially if it is a multi discipline case.

      Posted by Nancy on 11/2/2014 3:45 AM

    • Completely agree, Nancy. If PT, or other discipline, is the only being utilized, the previous re-assessments are sensible. However, as soon as 2 disciplines, or 3, are included, the timeline is completely impractical.

      Posted by Preston Collins, PT, DPT on 11/2/2014 3:35 PM

    • I would like to thank the APTA in there efforts to support the Home Health PTA. The APTA recommended to CMS that reassessments be performed every 30 days, not 14 days as the proposed rule suggested. Thank you CMS also, this is an efficient and sensible solution to the 13/19th visit requirement..I believe patient care will be enhanced by this rule: simplified scheduling process and more visits that focus on treatment as opposed to a required assessment. Also, PTA's perform assessments as part of our treatment(s) and we document based on the data collected. Anyway, wise decision and job well done...Thank you..PTA, Ocala, FL.

      Posted by Matt on 11/10/2014 7:30 PM

    • Totally agree with you Nancy. The plotting of the schedules gets messed up especially if the 13th and 19th reassessments happen to be a MV (missed visits) specially for patients receiving multiple discipline interventions.

      Posted by Diane on 12/11/2014 10:42 AM

    • How does this work with recert's? If a patient was on service prior to the new year, and they are recerted into the new year, does the new rule take effect or do they continue with the old rule?

      Posted by Ryley on 1/5/2015 7:05 AM

    • Does 30-day new rule only apply to SOC's that start on or after 1-1-15?

      Posted by Tasha on 1/8/2015 3:15 PM

    • Can the 30 day reassess be done anytime on or before 30 days? And is the next reassess 30 day count to begin on the day after each prior reassess?

      Posted by Melissa on 1/14/2015 10:06 AM

    • I was just told by my director that you have to continue with 13/19th re-evaluation with any patient you had begun a start of care before 1/1/15, but once that 60 day time is over, it only has to be every 30 days. Therefore within 60 days all of your patients should be every 30 days but the next few months any patients you had before 1/1/15 you still have to do 13/19th re-evaluations until they are in their next 60 day certification period.

      Posted by Joan Begliomini on 1/18/2015 3:19 PM

    • Does the 30-day new rule only apply to SOC's that start on or after 1-1-15?

      Posted by Chuks Udenkwo on 1/28/2015 1:30 PM

    • I'm not sure where the PTAs and PT's who posted comments here work but my ability to effectively supervise the PTA's who carry out POC's within HHA's is severely compromised as it is. Now I have no way of following these patients care within greedy HHA's who will see this as a way to decrease costs by discharging the patient in less than 30 days. By the way PTA's are not legally allowed to assess a patient. A PTA may utilize the tests in the POC TO ASSESS THE EFFECTIVENESS OF THEIR TREATMENT ACCORDING TO THE POC. THIS IS NOT ASSESSING THE PATIENT!

      Posted by Gilberto Ramirez on 2/12/2015 8:59 PM

    • Regarding the 30 day rule for re-eval, do we start counting the eval date as DAY 1 , and count exactly 30 days to a specific date. What if we don't do the visit on that exact date. Can we do it a day before or a day after that 30 day count is. Let's say the re eval 30 day is on 3-5-15 but our actual visit is 3-6-15 and the previous visit was 3-2-15. When do we do the re eval, on 3-2-15 or 3-6-15 ????

      Posted by nadine on 2/27/2015 1:31 AM

    • I am a PTA. I know this is not the topic but who and where should I send correspondence to change the Medicare law back to it's previous state where PTA's can perform tx with a PT being reachable by phone and not being in the location at all times. I have been licensed and practicing for over 4 years. I work at several of our satelite clinics. When this law was written my hours have been drastically cut to where I will have to give up my benefits. I am a skilled, professional, talented PTA that is no longer able to work with my favorite pt demographic and provide for my family due to this change. I am 32, married and had my first child 4 months ago. Due to this change we are really struggling. My husband is also in the " human helping field" as a teacher and this has created a financial blow to our family especially with a new infant. I am a therapist pt (especially the Medicare demo) ask for and now they are subject to a new grad PT who does not treat them with the respect they deserve. I am a professional and to be lumped in the same category as an Aide is disrespectful and harmful for Physical therapy in general. This is something that needs to be closely looked at and changed. The leaders and decision makers in this field have made this profession a dead end, when it does not need to be. A PTA must start from the beginning in order to proceed to a DPT. This is something that also needs to be evaluated. Experience is always the best way for success and PTA's should have a bridge to advance. I am not saying to make it easy but streamlined. A diploma and a title does not always make the best therapist. Thank you for reading.

      Posted by Kelley on 3/19/2015 1:01 PM

    • Use of Physical Therapist Assistants (PTAs) Under Medicare Please note that physical therapists are licensed providers in all states and physical therapist assistants are licensed providers in the majority of states. As licensed providers, the state practice act governs supervision requirements. Some state practice acts mandate more stringent supervision standards than Medicare laws and regulations. In those cases, the physical therapist and physical therapist assistants must comply with their state practice act. For example, in a skilled nursing facility in New Jersey, a physical therapist must be on the premises when services are furnished by a physical therapist assistant despite the fact that Medicare requires general supervision. New Jersey's state practice act requires direct supervision rather than general supervision, and therefore, the physical therapist and physical therapist assistant would have to comply with this requirement. Certified Rehabilitation Agency (CRA) CRAs are required to have qualified personnel provide initial direction and periodic observation of the actual performance of the function and/or activity. If the person providing services does not meet the assistant-level practitioner qualifications in 485.705, then the physical therapist must be on the premises. Comprehensive Outpatient Rehabilitation Facility (CORF) The services must be furnished by qualified personnel. If the personnel do not meet the qualifications in 485.705, then the qualified staff must be on the premises and must instruct these personnel in appropriate patient care service, techniques, and retain responsibility for their activities. A qualified professional representing each service made available at the facility must be either on the premises of the facility or must be available through direct telecommunications for consultation and assistance during the facility=s operating hours. Home Health Agencies (HHA) Physical therapy services must be performed safely and/or effectively only by or under the general supervision of a skilled therapist. General supervision has been traditional described in HCFA manuals as Arequiring the initial direction and periodic inspection of the actual activity. However, the supervisor need not always be physically present or on the premises when the assistant is performing services. Inpatient Hospital Services Physical therapy services must be those services that can be safely and effectively performed only by or under the supervision of a qualified physical therapist. Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her physical therapy state practice act. Outpatient Hospital Services Physical therapy services must be those services that can be safely and effectively performed only by or under the supervision of a qualified physical therapist. Because the regulations do not specifically delineate the type of direction required, the provider must defer to his or her physical therapy state practice act. Private Practice Physical therapy services must be provided by or under the direct supervision of the physical therapist in private practice. CMS has generally defined direct supervision to mean that the supervising private practice therapist must be present in the office suite at the time the service is performed. Physician's Office Services must be provided under the direct supervision of a physical therapist who is enrolled as a provider under Medicare. A physician cannot bill for the services provided by a PTA. The services must be billed under the provider number of the supervising physical therapist. CMS has generally defined direct supervision to mean that the physical therapist must be in the office suite when an individual procedure is performed by supportive personnel. Skilled Nursing Facility (SNF) Skilled rehabilitation services must be provided directly or under the general supervision of skilled rehabilitation personnel. AGeneral Supervision@ is further defined in the manual as requiring the initial direction and periodic inspection of the actual activity. However, the supervisor need not always be physically present or on the premises when the assistant is performing services.

      Posted by Nilo Galang -> =KY^<K on 3/30/2015 9:34 PM

    • I am a physical therapist in IL, my question is about home health supervision visit done by PT for PTA. usually it is 6th visit from the day of evaluation. Since the changes of 1-1-2115 the supervision visit is merged with 30 day reassessment or it will remain the same on 3rd week (6th visit)?

      Posted by Muhammad Ali -> BHWbAF on 4/22/2015 9:03 PM

    • what about the Medicare lawsuit?

      Posted by Donna on 6/30/2015 11:10 PM

    • I have a question? Please help me. I have a patient with Physical therapy, but unfortunately she was placed on hold due to severe pain. Does a 30 day eval/re-eval/assessment has to be done???

      Posted by SANDRA TORRES on 7/1/2015 2:32 PM

    • Was the severe pain from a new diagnosis? If it is, then the patient would warrant a new evaluation, which will create a new 30 day period. If it was not, it would depend on the "hold" days or if the patient has declined or have a changed in functional status. In my agency we usually re-evaluate after a week of "hold" days, but again if the patient has a change of functional status, we re-evaluate the patient. I may be wrong in my assumption but I always believe to re-assess (not a full eval) a patient after a medical hold. So a re-assessment of the patient after a hold will count as a 30 day and will reset the count.

      Posted by Nilo Galang on 7/14/2015 12:34 PM

    • I wanted to clarify that as long as the next visit for a 30 day reassessment is done, that adheres to the rule. My example is: pt was on hold due to pain when 30 day Functional Reassessment should have been done. As long as the next visit is a Re-eval or Functional Reassessment by the PT, that follows Medicare Rule?

      Posted by Jennifer Nourse on 7/24/2015 3:38 PM

    • This is the Medicare rule (verbatim):"At least once every 30 days, for each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must provide the ordered therapy service, functionally reassess the patient, and compare the resultant measurement to prior assessment measurements. 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.." From your example,a patient was on hold that a 30 day assessment was to be done (again an assessment can be done at least once in every 30 days it does NOT say EXACTLY 30 days), so I would assume that it would follow Medicare rule, since a Therapist can NOT visit or treat the patient and functionally measure and compare to prior assessments. I would write a supporting documentation though with a simple statement saying "Unable to do a 30 day re-assessment secondary to patient being on medical hold. Patient will be re-assessed on next visit." Hope that helps.

      Posted by Nilo Galang on 7/26/2015 7:55 PM

    • When do the 30 days RE begins? For example, if a PT did a recert on 9/17 and EOC is 9/19, new cert start on 9/20 with the 1st PT visit done on 9/22, do the 30 days RE count start on 9/18 which is still on the old cert or on 9/23 after the 1st visit on the new cert. Thanks

      Posted by Amanda on 10/12/2015 10:31 AM

    • What is the difference between a re-eval and a re-assessment? I have been doing re-evals every 30 days, but maybe I should have been doing Re-assessments. Also, and more importantly, does it say anywhere in the rules that a PT/OT/SLP Eval/Re-eval has to be done at the beginning of every new 60 day Oasis-C Certification period?

      Posted by Laurie on 10/17/2015 4:51 PM

    • Regarding reassessments 1. initial eval 9-1 2. no reassessment completed 3. last therapy visit within 30 day was routine visit on 9-28 4. patient was discharged on 10-5 5. no missed visits or rehospitalization Question is "which visit is noncovered? the 9-28 visit or the 10-5 discharge visit"?

      Posted by Virginia Bowen on 10/22/2015 11:05 AM

    • The Medicare "reassessment at least once every 30 days" requirement for therapy in home health applies to therapy, NOT to be confused with home health Medicare days or 60-day day episode. So, the count would begin on 9/18. Ex. Reassessment day: 9/17 Day 1: 9/18 to Day 30: 10/17 Reassessment should be done (again)between Day 1 and Day 30 to satisfy the requirement. Please also note that "For multi-discipline therapy cases, a qualified therapist from each of the disciplines must functionally reassess the patient...."

      Posted by NG on 10/23/2015 10:23 AM

    • Re "What is the difference between a re-eval and a re-assessment? I have been doing re-evals every 30 days, but maybe I should have been doing Re-assessments." Per Medicare definition: “EVALUATION is a comprehensive service provided by a clinician that requires professional skills to make clinical judgments about conditions for which services are indicated based on objective measurements and subjective evaluations of patient performance and functional abilities. Evaluation is warranted e.g., for a new diagnosis or when a condition is treated in a new setting. These evaluative judgments are essential to development of the plan of care, including goals and the selection of interventions.” And “Assessments shall be provided only by clinicians, because assessment requires professional skill to gather data by observation and patient inquiry and may include limited objective testing and measurement to make clinical judgments regarding the patient's condition(s). Assessment determines, e.g., changes in the patient's status since the last visit/treatment day and whether the planned procedure or service should be modified. Based on these assessment data, the professional may make judgments about progress toward goals and/or determine that a more complete evaluation or re-evaluation is indicated. "

      Posted by NG on 10/23/2015 12:16 PM

    • According to Medicare "A. Initial Episodes The "From" date for the initial certification must match the start of care (SOC) date, which is the first billable visit date for the 60-day episode. The "To" date is up to and including the last day of the episode which is not the first day of the subsequent episode. The "To" date can be up to, but never exceed a total of 60 days that includes the SOC date plus 59 days. B. Subsequent Episodes If a patient continues to be eligible for the home health benefit, the HH PPS permits continuous episode recertifications. At the end of the 60-day episode, a decision must be made whether or not to recertify the patient for a subsequent 60-day episode. An eligible beneficiary who qualifies for a subsequent 60-day episode would start the subsequent 60-day episode on day 61. The "From" date for the first subsequent episode is day 61 up to including day 120. The "To" date for the subsequent episode in this example can be up to, but never exceed a total of 60 days that includes day 61 plus 59 days. NOTE: The certification or recertification visit can be done during a prior episode. The Medicare Conditions of Participation, at 42 CFR 484.55(d)(1), require that the recertification assessment be done during the last 5 days of the previous episode (days 56-60)." I'm not sure if I answered your question but I hope this helps. P.S. To count the 60 days cert period, I used to do this neat trick (it usually works):): + 2/- 2. Ex.HHA SOC is 9/20. So 9 + 2 = 11, 20 - 2 = 18. 60th day is 11/18 and recertification can be done from 11/14 to 11/18.

      Posted by NG on 10/23/2015 1:04 PM

    • 10/5 discharge visit. Initial eval was 9/1 Day 1: 9/2 to Day30: 10/1. Discharged: 10/5 Reassessment should have been done between 9/2 to 10/1. The last visit 9/28 should be a discharge date.

      Posted by NG on 10/23/2015 1:19 PM

    • Does anyone know if this applies to pediatric clients on Medicaid? One of my HH companies say no and one is having me do the 30 day assessments even thought the 14/19 days didn't apply before this change. Any one have thoughts on this? I sure would appreciate any input.

      Posted by Terri Sadecki on 12/12/2015 4:59 PM

    • Here is my take on this, according to the CMS final rule it states “…As required by section 3131(a) of the Affordable Care Act and finalized in the CY 2014 HH final rule, Medicare and Medicaid Programs; Home Health Prospective Payment System Rate Update for CY 2014, Home Health Quality Reporting Requirements, and Cost Allocation of Home Health Survey Expenses’’….” I would assume that MEDICAID programs are affected as well. The 30 day reassessment rule is from CMS. For Home Health agencies that participate in Medicare and Medicaid programs should follow that rule. I think it is up to the agency’s policy IF they want an added reassessment or paperwork (like14th or 19th visit). There is no rule for that, as long as they (HHAs) follow the 30 day reassessment rule. Although, I think it doing such IS a waste of the therapist time rather than focusing on valuable healthcare given to the patient, which is by the way one of the reasons why they changed the rule.

      Posted by NG on 12/16/2015 5:59 PM

    • If I have a patient that has been seen throughout the episode and now it is time to recertify patient. Patient no longer needs SN and PT will continue on new episode. Do I have to have a new evaluation in the new episode or will the re-assessment with new frequency be enough for the new episode? Also in general with new episodes do we need a whole new assessment?

      Posted by Alina on 2/29/2016 7:08 PM

    • The following episode is called a re-certification and warrants a re-certification OASIS, due on the last day of the current episode OR can be done within 5 days before the end date. If only the PT will continue, he/she will do the re-certification OASIS AND the PT re-assessment or re-evaluation. A Medicare patient needs: 1. Start of Care OASIS / resumption OASIS - to start or resume (ex. if patient was re-hospitalized during current episode) an episode. 2. Re-certification OASIS / Follow up OASIS - 2nd episode (no discharge). 3. Discharge OASIS - patient discharge - end of episode. 4. Transfer OASIS - ex. patient went to hospital. By saying assessment, I assume you mean OASIS (Outcome and Assessment Information Set). REMEMBER that a PT assessment or evaluation is different from an OASIS and has to be done if a patient needs physical therapy. I understand the confusion since some of the "market" OASIS forms include PT assessment like Briggs or Medpass (as long as it says PT OASIS or OASIS with Physical Therapy assessment). If its ONLY an OASIS form (ex. nursing OASIS) which can also be done by a PT, a PT evaluation is needed. Remember you need a PT reassessment once in every 30 day. I hope I answered your question. (My answers are mostly taken from CMS home care manual).

      Posted by N on 3/17/2016 3:40 PM

    • I had a patient request that therapy be held for one week d/t pain. The week requested was at the 30 reassessment period. If the reassessment was not done and a PTA went out to see that patient w/o knowledge that the 30 day assessment was not done, can I still bill the PTA visit(s) that were done prior to the 30 day assessment that was not done. Thank you. Stacie Ahrendts

      Posted by Stacie Ahrendts on 3/29/2016 10:23 AM

    • Similar question was posted to MEDICARE. The following was Medicare's answer: "CMS believes that the policy that requires a qualified therapist to perform the necessary therapy service, assess the patient, measure, and document the effectiveness of the therapy at least once every 30 days during a course of therapy treatment is essential to ensuring that effective, reasonable, and necessary therapy services are being provided to the patient. In the case of a home health patient where the therapy goals in the plan of care have not been met, but the doctor has instead ordered a temporary interruption in therapy, we would usually expect that the unique clinical condition of the patient would enable the home health agency to anticipate that an interruption in therapy may be needed. In such cases, the HHA should ensure that the requirements are met earlier than the end of the “at least every 30-days” period to ensure the HHA meets this requirement. Where unexpected sudden changes in the patient’s condition result in a stop therapy order, we would expect to see documentation and evidence in the medical record (including a physician order to stop therapy) which would support an unexpected change in the patient’s condition which precludes delivery of the therapy service. We will modify our manual to describe that in such documented cases, the 30-day qualified therapist visit/assessment/measurement requirement can be delayed until the patient’s physician orders therapy to resume."

      Posted by NG on 4/4/2016 10:56 AM

    • Short answer to your question: YES, prior PTA visits are billable. Best practice is to provide documentation as to why and as Medicare suggested.

      Posted by NG on 4/4/2016 11:02 AM

    • I work in Acute Care Setting. Is a PTA able to resume treatment on a post surgical pt without PT reassessment. Minor surgery like pegs, trachs, wound closure, debridement, etc?

      Posted by Char on 4/29/2016 8:57 AM

    • does 30 days physical therapy re-evaluation fulfill the supervisory visit needed for physical therapy assistant?

      Posted by khaled Hussein on 6/6/2016 7:09 PM

    • Must 30 day reassessments be signed by the physician for HHA requirements?

      Posted by jennifer on 6/9/2016 12:54 PM

    • Q: I work in Acute Care Setting. Is a PTA able to resume treatment on a post surgical pt without PT reassessment. Minor surgery like pegs, trachs, wound closure, debridement, etc? A: No

      Posted by NG on 7/15/2016 10:19 AM

    • Q: does 30 days physical therapy re-evaluation fulfill the supervisory visit needed for physical therapy assistant? A: Re-evaluation/reassessment IS for patients. IF the re-evaluation/reassessment form includes a separate form or section for PTA supervisory visit then yes.

      Posted by NG on 7/15/2016 10:24 AM

    • Q: Must 30 day reassessments be signed by the physician for HHA requirements? A: No, it is not a requirement for HHAs. IF there is NO new order (e.g., change in treatment, change in time frame, etc.) the initial signed POC (that includes the original PT order) will suffice BUT for best practice, our HHA sends the physician a copy of the reassessment and have him/her sign it.

      Posted by NG on 7/15/2016 11:01 AM

    • When does the home health visit start: Some say computer visit should not be started til you see the white of the patient's eyes.

      Posted by Barbara Trentadue on 9/30/2016 10:55 AM

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