There’s little doubt that if a vote was taken to nominate the most despised regulation in the home health industry, the 13th and 19th visit therapy re-assessment requirement would be the favorite to take home the grand prize. The Centers for Medicare & Medicaid Services (CMS) enacted this requirement as a way to prevent unnecessary therapy utilization. It became a concern, and not without merit, after CMS had endorsed changes to the reimbursement formula providing for increased compensation following home health therapy visit 13 and visit 19.
As with any regulation, the 13th and 19th visit re-assessment requirement aims to constraint certain practices and coerce a certain action. Its premise is just as it seeks to prevent fraudulent services paid for by the taxpayers. Regulations have its costs and benefits. An efficient regulation will have its benefits exceed the cost. By that measure, the 13th and 19th visit requirement is hardly a good deal. Given the reality of how diverse home health care teams can be and how the needs of patients could change, the costs of complying with this requirement are significant for both home health agencies and therapy companies. As for the benefits, how does it punish the bad guy?
Could CMS have devised a better approach to prevent unnecessary therapy utilization? One that does not exert significant compliance costs onto those who play by the rules and is actually more effective in achieving the desired outcome? Is CMS indirectly pursuing other goals? Whatever the answers might be, home health agencies and therapy companies must find a way to adapt while keeping their costs at a minimum. Fortunately, ingenuity always finds a way to overcome bureaucratically imposed challenges. therapyBOSS is a prime example in that regard. We’ve made it ridiculously simple for therapy companies, therapists, and home health agencies to stay on top of the 13th and 19th visit requirement. Clinicians are alerted automatically about upcoming re-assessments up to 7 days ahead of time! Therapy companies and home health agencies can monitor re-assessment compliance in real time with just a couple of clicks. Corrective action can be taken at any time. Behind the scenes, therapyBOSS is hard at work monitoring ongoing activity and accounting for every situation without fail.