On November 2, CMS has released the final rule for the Home Health Prospective Payment System (HH PPS) for 2013. The rule contains a few revisions regarding therapy reassessment requirements. Here’s the rundown of the three things you need to know:
- If a reassessment visit is missed, therapy coverage will resume with the visit during which the therapist completes the late reassessment. Presently, the late reassessment visit doesn’t get covered.
- If a reassessment visit is missed in a situation with multiple therapy disciplines involved, coverage will cease only for the discipline out of compliance. As long as the other disciplines complete the required therapy reassessments on time, therapy services provided by them will continue to be covered. Presently, all therapy visits subsequent to a missed reassessment visit are denied for coverage.
- Since the establishment of the 13th and 19th visit therapy reassessment rule, there has been ambiguity related to when precisely the reassessment visits must occur in instances with multiple therapy services involved. CMS recognized that it bears responsibility for the confusion and has cleared it up in the new rule by stating that “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.” CMS has further clarified that in circumstances where the frequency, as ordered by a physician, does not make it feasible to perform the required reassessment exactly on time, it would be satisfactory to complete the reassessment close to the 14th Medicare-covered therapy visit, but no later than the 13th Medicare-covered therapy visit; or close to the 20th Medicare-covered therapy visit, but no later than the 19th Medicare-covered therapy visit.
The therapy reassessment requirement revisions are positive on the whole. A more liberal approach to penalizing for missed reassessments is welcome. Having a clear understanding of when reassessments must be performed with multiple disciplines involved is helpful. Even with a caveat for discordant frequencies, make no mistake it’s still paramount to get the reassessment completed on exactly visit 11, 12, and 13 in the case of 13th visit reassessment and 17, 18, and 19 for 19th visit reassessment. Don’t agree? Ask yourself if you want the agency to be proving to their fiscal intermediary that an untimely reassessment visit was justified while their reimbursement is held up.
Therapy reassessment compliance will continue to cause headaches for therapy companies and home health agencies. therapyBOSS can eliminate the pain. It handles every scenario pertaining to the 13th visit, 19th visit, and 30 days reassessment requirement and alerts therapy companies, therapists, and home health agencies appropriately. Even in situations when reassessments are not performed on time, therapyBOSS makes it possible to easily correct the problem within the boundaries of clinical norms.
The entire CMS 2013 PPS final rule is available here. Therapy policy changes start on page 122.