The Centers for Medicare and Medicaid Services (CMS) recently updated its therapy question-and-answer document that clarifies several provisions regarding the therapy functional reassessment requirement under the Medicare Home Health Part A benefit. Medicare pays only for visits in which the therapy reassessment is done in compliance with the Medicare regulations. Noncovered therapy visits are not to be included in the counting of therapy visits for the purpose of determining when certain required therapy reassessment visits need to occur.

In the Q&A, CMS clarifies that home health agencies and therapists should not change the number of therapy visits a patient receives based on whether prior visits were covered by Medicare, and patients should receive only the number of therapy visits delineated in the plan of care. The Q&A also provides detailed examples of when the therapy reassessment is missed or is not compliant and its subsequent effect on the counting of Medicare-covered therapy visits in single and multiple therapy cases.

CMS requires that the patient's function must be initially assessed and periodically reassessed by a qualified therapist of the corresponding discipline for the type of therapy being provided (ie, physical therapy, occupational therapy, or speech-language pathology services). When more than 1 therapy discipline is being provided, the corresponding qualified therapist would perform the reassessment during the regularly scheduled visit associated with that discipline that is scheduled to occur closest to the 13th and 19th visit, but no later than the 13th and 19th visit.