Clarifying home health reassessment rules and misconceptions

[Guest guest]

I wanted to post this for anyone interested. I have noticed posts off and on

regarding the medicare home health reassessment rules and some posts are vague

and occasionally incorrect. Here's a review of the rules with examples of

problems that arise.

Single therapy discipline:

- Therapy services which are provided by a single discipline (PT,OT, or ST) must

document a functional reassessment on exactly the 13th, and 19th visits to

justify continued care. The exception is if you are in a designated " rural " area

geographically. If so you can do the reassessment on the 11th-13th visit, and

17-19th visit. You have to do a 30 day reassessment for patients as well. This

is specific to 30 days between reassessments, not every 30th calendar day.

Therefore anytime you complete a reassessment, the 30 day " clock " starts over.

However if you complete a 30 day reassessment prior to the 13th and 19th visits,

you must still complete reassessments on the exact 13th and 19th visits.

- Misconceptions -1.  many think you must do 30 day reassessments on exactly the

30th day or close to it. These can be done at any time, and the 30 day " clock "

resets. 2. Many think that a new certification period " resets " the visit counts.

This is true for visit count for the 13th and 19th visits but NOT for 30 day

reassessments. The 30 day reassessments are continuous across cert periods. So,

if you recertify a patient 4 days prior to the new certification period, your 30

day reassessment is based on the date of the completed recertification, not the

first day of the new cert period.

 

Multiple therapy disciplines:

- Therapy services provided by multiple disciplines (PT, OT and/or ST) are

required to document functional reassessments close to but no later than the

13th and 19th visits.

- Misconceptions - 1. Some HH agencies think that multiple disciplines must time

the reassessments within the range of the 11th, 12th, and 13th visits, or 17th,

18th, and 19th visits. 2. Others take that one step further and have therapists

time reassessments on exactly the last consecutive visits prior to the visit

reassessment requirement - ie PT, ST and OT are seeing a patient, and are

required to reassess on the 11th, 12th and 13th visits. Neither scenarios are

correct. The " Close to " rule  in no way specifies visit numbers, only stating " no

later than " the 13th and 19th visits. The error evolved from HH agencies and

even billing software publishers interpreting the reassessment visit range

for  " single therapy discipline in a rural area " ( 11th, 12th and 13th) and

applying this range to define the " close to " rule. With multiple disciplines, it

is simply " close to, " sometimes it can be warranted to reassess a patient as

early as visit 7 or

8. CMS recognizes the likelihood of disruption of patient care if an agency had

to coordinate 3 disciplines on consecutive visits.

ie - PT, OT and ST are treating a CVA patient. PT/OT are 3x per week (MWF) and

ST is 2x per week (T-th). The patient is seen on a thursday by the speech

therapist at visit #8. The family tells the ST that they will not be available

the following Tuesday because of a doctor visit. They decline moving the visit

because they feel seeing all three clinicians the same day is too much. The ST

should do an early reassessment on visit 8 because with PT and OT in, the

patient would be seen for visit 9-14 by the time the patient/family allows a

return.

3. With multidiscipline therapies reassessments are always done  " close to " the

13th and 19th visits. This is still correct but one error commonly occurs. When

one of the therapies discharges a patient the remaining discipline often still

utilizes the " close to " rule. At anytime, if one therapy discipline discharges a

patient, the remaining therapy discipline now must follow the single discipline

rule and reassessments must be done on exactly the 13th and 19th. For example,

PT and OT are seeing a patient, PT performs a reassessment on the 11th visit,

the OT discharges on visit 12, the PT must document another reassessment on the

13th visit because as of the 13th visit, PT is the only therapy discipline.

 

Bisesi MPT

PT contractor

Winter Haven, Fl 33884