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  • CMS 2015 Home Health Payment Proposal Estimates .3% Net Decrease, Requires Reassessments Every 14 Days

    Estimating a net decrease of .3% to home health agencies for next year, the Centers for Medicare and Medicaid Services (CMS) has released its proposed rule for the Home Health Prospective Payment System (HH PPS) for 2015. The rule proposes a home health market basket update of 2.2% adjusted for multifactor productivity as mandated by the Affordable Care Act (ACA), and includes a requirement that functional therapy reassessments be conducted every 14 days.

    CMS will implement the second year of the ACA-mandated 4-year phase-in for rebasing adjustments to the HH PPS payment rate by decreasing home health payment by 3.5 percent. The proposed national, standardized 60-day episode payment for 2015 is $2,922.76. The proposed per-visit amount for physical therapy in 2015 is $139.73 for home health agencies (HHAs) in compliance with quality reporting requirements.

    Other rules have been proposed it the following areas:

    • CMS proposes to simplify the home health therapy functional reassessment by reversing the current requirements to complete the assessment at the 13th and 19th visits and/or at least every 30 days and instead require a qualified therapist (rather than an assistant) from each discipline to provide the therapy and functionally reassess the patient at least every 14 days. The requirement would apply to all episodes regardless of the number of therapy visits provided. The current documentation requirements to use objective measurement tools in this assessment would not change.
    • CMS proposes significant changes to the physician face-to-face encounter requirements. First, CMS would eliminate the narrative requirement. Second, CMS would consider only medical records from the patient’s certifying physician or discharging facility to determine if the patient is eligible for Medicare home health. Third, CMS would consider the physician Medicare claim for certification/recertification for home health services (not the face-to-face encounter visit) a noncovered service if the HHA claim was not covered because the patient was found ineligible for home health.
    • CMS proposes that HHAs submit both admission and discharge outcome and assessment information set (OASIS) assessments for a minimum of 70% of all patients with episodes of care occurring during the applicable reporting period. This threshold would increase by 10% each year until reaching a cap of 90% in 2017.

    Last, CMS invites comments on a pilot value-based purchasing (VBP) model for HHAs that would begin in 2016. CMS hopes to test the model in up to 8 states.

    APTA staff is conducting a complete review of the proposed rule and will provide a detailed summary in the coming days.

    Comments

    • 1. What is the VBP model? 2. The proposed ruling would phase out PTA's?

      Posted by Adriana on 7/12/2014 10:04 PM

    • I would like the APTA which I have paid dues for since 1995, for once try and stand up and protect the PTA position!

      Posted by Richard Haynes on 8/12/2014 7:12 AM

    • This will be detrimental to the home health PTA. The PT will effectively need to conduct a re-assessment visit after every 3 PTA visits on a frequency of 2x a week....This will cost PTA jobs and have no effect and on pt care....Home health PT tends to be very simply clinically and does not require the constant re-assessments of the PT. We are basically doing exercises with the elderly, PTAs that have years experience and a clinical education do not need someone to constantly check up on them to do exercises with the elderly..Some P.T's are not very good at there jobs and actually get in the way of the PTA performing effective treatments...

      Posted by Matt on 9/18/2014 12:33 AM

    • Im a PT and my husband is a PTA. I keep us both busy full time in home care. Reassessment every 14 days!!! I wont do it. That's insane and completely unnecessary. So I eval, 3 visits with PTA, I eval, 3 visits with PTA and so on. How am I suppose to keep up with my own schedule. Inconsistency does not provide good patient care. If this goes through it looks like the end of the PTA in homecare. I read about this just 2 hour ago and already my husband is looking into a career change. As a strong democrat I've always been annoyed by the tern "too much regulation". Well know I get it. And yes Matt, your right. Home care is pretty brainless. I remember 15 years ago when I was in PT school there were a number of PTA in class who would not join the APTA because of the poor support of the PTA position. Looks like nothing has changed.

      Posted by Jennifer on 10/3/2014 7:28 PM

    • What a absolute shame. PTAs go to school for two years and essentially have the same degree as a nurse but in PT and they do this to us? a 14 day time period would be worse not better then 13 and 19th reassessment. It would absolutely make it a nightmare for PT's. Forcing them to see patients after every 3 visits at say 2 x per week. It would not improve pt care having multiple people coming in to treat a pt. My patients hate it now. Imagine a PT having a case load of 1 or 2 ptas and having to do 15-30 reassessment visits a week how ridiculous. So. basically hhc businesses will stop hiring PTA's and that will be the end of that. It will cost the businesses more because they will have to pay for their entire staff to be all PTs. All in the name of what CMS says improved quality of care. Dont they realize the quality of care is great already. Wouldn't it be better quality of care to just not use PTA's I would think so? So, essentially, cms will personally destroy the PTA position in home care. I find it sad that a home health aid can transfer these "fragile" patients (with sometimes orthopedic surgeries) in and out of showers and help them get from room to room and perform exercises that the PT and PTA provide in the form of a hep and yet not have to have a direct supervisory visit though someone who has a 2 year degree and tons patient experience has to have be so closely supervised. I could see maybe every 3 weeks but every 2 is completely unrealistic. That is why the 13th and nineteenth doesn't work its not the confusion just too problematic and patients don't like it. What i would like to know is just what is it that CMS is so afraid PTA's are doing to warrant this scrutiny? Are we doing surgery on these patients? Perhaps twisting their new knee replacement? Killing them with exercises? OK, so maybe they feel threatened we would? well if that's the case, then couldn't we do that in one visit? Abe R

      Posted by Abe on 10/3/2014 9:04 PM

    • I guess they feel we are secretly trying to kill people. I guess we will have to perform that now in less then 3 visits......National home care and CMS are ridiculous and foolish and base their redonkulous ideology on improved health care. Wouldn't it improve home care if there wasn't any PTA visits in home care? of course it would. Yes, no one will use PTAs anymore and yes it'll cost businesses more but hey who cares if people lose work right, and yes for years PTAs have delivered poor quality of care. Because yes its a safety thing and yes its the right thing to do.....

      Posted by Abe on 10/3/2014 9:58 PM

    • Yes I agree as well as PTA COTA's also will be out of jobs. Every 14 days is unrealistic. Every 3 weeks is much more objective and realistic. Patients absolutely hate the reassessments and comments on how fast they have to be done and feel they are not getting a chance to get better

      Posted by jennifer young on 10/7/2014 6:40 PM

    • This proposed rule change will increase therapy visit numbers in home health. There is a large majority of PT's that are doing nothing more that evaluation visits with minimal to no treatment/education during those visits. CMS, a patient will no improve by a qualifying therapist going out and checking MMT, ROM, assistance level, and perform functional test. A 30-day reassessment or 10 visit reassessment (which ever comes first) makes the most since. It takes time to show functional progress. Dear CMS, you just increased the visit frequency to 3 times a week. Just wait and see.

      Posted by Richard Crawford on 10/18/2014 12:09 AM

    • Yes, All of you are right. I can guarantee that I will no longer be using PTAs if this goes into effect. Imaging evaluating a pt on Monday. My reassessment would have to be done on Monday 2 weeks later. If I do it on Tuesday because a pt cancels or I am just too buisy, I am now out of compliance. Therefor I know my office will schedule the re-eval the week beforehand. The reality is I will be doing reassessments after just 2 visits with the PTA. Pts are going to be very annoyed. Richard you are right. Therapists will just start scheduling pts 3 times a week. And PTAs will be out of work.

      Posted by Amber on 10/27/2014 5:06 PM

    • It will make scheduling easier. Washington state did a "every 5th visit" requirement for PT visits. Once we got into the rhythm it was sooooo much easier than the 13th then 19 then OMG 30 day unless .... and of course add the other two disciplines to the mix and the PTA gets to see a pt, oh let me see every 3 or 4 visit if they could scoot in before the COTA. Having to have the disciplines share the assessment days is stupid but it is better than how it is now. By the way don't think that the CMS gives a rip about PT vs PTAs OTs VS COTA. It is a lot cheaper to pay a PTA than a PT so financially it does not help anyone to have the PTs going out to see pt's more often. Anyone out there who doesn't remember when seeing a pt indifferently and PT's just signing off on more orders without really knowing what was up with the pt's was the norm, really hasn't been doing therapy long enough. Some of the posts sound as if the PT's are looking for a way to eliminate PTAs and it appears that a lot of PT's and PTAs are letting themselves get suckered into believing that this new system is worse than the one before. Don't be saps. Do the math! And yes we may start seeing more 3 times a week visit which for some of the HH pts is far more appropriate than 2x.

      Posted by Nonnye on 10/31/2014 10:34 PM

    • Good news PTA's and COTA's...Final rule is out and the 13th and 19th are gone and reassessments will be required every 30 days. Great News, thanks APTA and CMS for your efforts...This move is fair for PT's, PTA's and most importantly patients...Excellent news..

      Posted by Matt on 11/5/2014 11:34 PM

    • In my opinion the PTA position should be abolished. This field is too complex for a 2 year degree.

      Posted by jg on 3/16/2015 7:09 AM

    • So are PTA's jobs safe or did they pass that law? I'm currently going to PTA school and would really like to know if I should get out while I still can

      Posted by Amanda on 1/10/2016 3:55 PM

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