CMS Clarifies Implementation Date for Home Health Functional Reassessment Requirements for 2013
As a
follow-up to the issuance of the Home Health Prospective Payment System
Calendar Year (CY) 2013 Final Rule, the Centers for Medicare and Medicaid
Services (CMS) has updated its website to clarify that the therapy provisions
will be effective for episodes beginning on or after January 1, 2013. This
clarification can be found under the first bullet on the CMS HHA Center Webpage.
In the CY 2013 final rule published November 2, CMS finalized
3 revisions regarding the requirement that a qualified therapist complete a
functional reassessment of the patient at the 14th and 20th visits and every 30
days:
1.
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 the late
reassessment.
2.
When
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.
3.
In
cases where the patient is receiving more than one type of therapy, qualified
therapists must 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. However, CMS also states in
instances in which patients receive more than one type of therapy, if the
frequency of a particular discipline, as ordered by a physician, does not make
it feasible for the reassessment to occur during the specified timeframes
without providing an extra unnecessary visit or delaying a visit, then it will
still be acceptable for the qualified therapist from each discipline to provide
all of the therapy and functionally reassess the patient during the visit
associated with that discipline that is scheduled to occur closest to the 14th
Medicare-covered therapy visit, but no later than the 13th Medicare-covered therapy
visit. Likewise, a qualified therapist from each discipline must provide all of
the therapy and functionally reassess the patient during the visit associated
with that discipline that is scheduled to occur closest to the 20th
Medicare-covered therapy visit, but no later than the 19th Medicare-covered
therapy visit.
APTA is
working with CMS to address issues that may arise regarding implementation of
these provisions.
For a
comprehensive summary of the final rule, visit APTA's website. E-mail advocacy@apta.org with questions regarding
implementation of the 2013 functional reassessment requirement changes.