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  • 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.


    • I need clarification on two regulations. 1. If a patient is recertified (new 60 day episode) , the 30 day calendar tracking continues into the new episode. Or does it start at recert date. 2. If a therpist discharges a patient before the an assessment is due, say visit 9, do they need to do a reassessment at d/c?

      Posted by Maggie Kniele on 12/4/2012 1:25 PM

    • (1) The requirement for the qualified therapist to reassess the patient at least every 30 calendar days is not reset due to the certification of a new 60 day episode by the physician. The "30 day clock" runs from the time the therapist completes the reassessment until the next 30 day interval – regardless of multiple episodes of care. Additionally, please note that the 30 day requirement is for each discipline separately, which is slightly different than the requirement to complete the functional reassessment at the 13th and 19th visit, which is the combined count of all therapy visits by all disciplines. (2) No, there is no need for the qualified therapist to complete a functional reassessment as the patient did not meet the 13th visit threshold.

      Posted by News Now staff on 12/7/2012 3:16 PM

    • If a therapist performs a recert within the 5 day window of the episode does that visit count as 1 for the new cert or does that fall in the prior episode count.

      Posted by Ryan McElhinny on 3/29/2013 1:05 PM

    • I wanted to know if we have PT and OT and we have a total of 9 visits together combined and patient goes into the hospital, when we perform a ROC and PT and OT go to perform Post Hospital Re Evaluation do we start the 13th and 19 count all over or do we still count total visits from initial evaluation and POC.

      Posted by Kimberly Galvan on 10/9/2013 3:27 PM

    • I would like clarification; PT, OT and ST are treating the patient. We performed 8 visits, then the patient was hospitalized. ROC was done, and therapy went out to do new evals visits 9, 10, 11 - can we use the 9th and 10th eval visits as re-assessments?

      Posted by Stephanie Hansen on 10/30/2013 9:17 AM

    • My question is similar to the above question by Stephanie Hansen on 10/30/13. Does an evaluation and/or a re certification done by the therapist count as a FRA?

      Posted by Barbara Lynch on 1/6/2014 6:31 PM

    • I would just like clarification, s/p hospitalization does the count for the 13th/19th restart. Meaning does the ROC PT eval and ROC OT eval then become #1 and #2 or do we continue the count from the very first evaluation?

      Posted by Vanessa on 1/26/2014 2:45 PM

    • If a therapist does an evaluation on say 1/25 and nursing is in home also then nursing for some reason failed to do the recert which was due by or on 1/29 then can the PT turn his PT eval into a recert and patient being dicharged from nursing on 1/25 but PT still in home? This was January mistake discovered in February that Nursing did not recert when suppose to

      Posted by debbie on 4/17/2014 10:58 AM

    • Can someone clarify for me, please, if the 30 day reassessment has to be exactly on the 30th day?? or can it be a couple of days before? Thanks!!!

      Posted by sahily on 9/10/2014 9:47 AM

    • Does the Doctor need to signed the therapist assessment and re-evaluation is this mandatory? Thank you,

      Posted by Olga Miranda on 9/11/2014 4:31 PM

    • If the PT does not get the 30 day reassessment completed within the 30 day time frame does the PTA have to wait until the PT does complete an assessment before returning to treat the patient?

      Posted by Kim on 7/16/2015 2:05 PM

    • When a Registered therapist does his/her 11-13th reassessment note is she/he required to do a separate regular visit note?

      Posted by Daisy Saliganan on 1/4/2016 11:54 AM

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