Quick Tip for Meeting Home Health Therapy Requirements
by Jennifer Warfield, RN, BSN, HCS-D, COS-C
Education Director, PPS Plus Software
The new home health therapy reassessment requirements contained in the Calendar Year 2011 Final Home Health Rule became effective April 1. Is your home health agency prepared to meet these requirements?
Plan for more assessments & establish shorter goals
In addition to the long-standing requirement that each therapy patient be seen by the licensed therapist at least every 30 days, the 2011 Final Rule has even more stringent requirements. Minimal requirements for this regulation require that any time a patient has more than 13 therapy visits scheduled, and any time the patient has more than 19 therapy visits scheduled, the qualified licensed therapist (not an assistant) must reassess the patient before that 13th and 19th visit. (Keep in mind that the 13th and 19th therapy visit time points relate to the sum total of therapy visits from all therapy disciplines (PT, OT, and ST.) For patients being seen by more than one therapy discipline past the 13th visit or 19th visit, all continuing therapy disciplines must reassess the patient before the 14th (or 20th) visit, as close to the 13th or 19th target visit as is practically possible.
After review and reconsideration of the proposed rule, CMS granted some reprieve to agencies in RURAL areas (defined by CBSA codes) or for those where a situation outside of agency's control arises and a visit on exactly the 13th or the 19th visit is not possible. An allowance was made that a visit could be done after the 10th visit but not after the 13th or after the 16th but not after the 19th. This means that home health agencies must account for more frequent reassessments from each qualified therapist to justify the need for more therapy visits.
Proper planning is vital to an agency's success with this Final Rule. When you look at your goals today, they are long-term goals for the entire 60-day episode of care. With the new therapy requirements, you must show progress on the 13th and 19th visits. The key to compliance is to establish shorter goals when you do your original assessments.
When you complete a patient's original assessment, do not establish goals based on the patient's entire 60-day episode of care since it is very possible that a reassessment would be long-before the next recertification assessment is completed. Just as you may establish a goal that a stroke patient will be walking 150 ft within 60 days when he or she might actually get there in 30 days, plan for more frequent reassessments beginning April 1 and establish shorter goals.
How is your agency preparing to meet these new therapy requirements? Do you have any questions? Please submit your questions and comments here!
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About the author:
Jennifer Warfield RN, BSN, HCS-D, COS-C, is the Education Director at PPS Plus Software and an informational ally for hundreds of home health agencies across the country. As a homecare coding specialist, OASIS specialist and registered nurse with 30 years of clinical and management experience, she frequently conducts online and on-site educational workshops and is a regular guest speaker at numerous home care conferences.