CMS Responds to Therapy Assessment Questions

Therapy Assessment Visits and Emergent Coding Clarified

In the home health prospective payment system update for 2011, the Centers for Medicare & Medicaid Services (CMS) issued new therapy service reassessment requirements. According to these new Medicare fee-for-service payment regulations, home health patients receiving therapy services must have a reassessment and determination of progress toward goals at least every 30 days, as well as on the 13th and 19th aggregate therapy visit in each episode. Home health agencies have raised questions about scheduling these visits, particularly for patients receiving services from multiple therapy disciplines during an episode. The National Association for Home Care & Hospice (NAHC) received responses from CMS to the following questions.

  1. Q: If a patient is reassessed by a therapy discipline based on the 13th or 19th reassessment requirement prior to reaching the “at least every 30 days” [point], would the 30 day reassessment count begin again with the 13th/19th visit assessment? (In other words, whenever the patient is reassessed, does the every-30-days clock start over?)
    A: Yes, the 30-day clock restarts with every qualified therapist visit during which the therapist conducts an assessment and measurement and completes documentation.
  2. Q. If a patient is receiving multiple therapy services, must one of the qualified therapists’ actually conduct a reassessment visit on the 13th/19th, or may all of the disciplines conduct their qualified therapist reassessments on the visit closest, but prior to, the 13th/19th? In other words, if PT is 10th, OT is 11th, SLP is 12th, may the PTA visit on the 13th therapy visit as long as the qualified PT assessed the patient on the 10th visit?
    A: The visit close to (but before the 13th and 19th) is fine for all disciplines, when there are multiple disciplines.
  3. Q. When we count visits to determine when the next therapy assessment is due, do we count all visits or just billable visits?
    A: Count billable visits.
  4. Q. Are responses for M2310 selected because of the reasons the patient sought and/or received treatment in the emergency room (ER)? For example, a patient went to the ER because of flu symptoms, nausea, vomiting, and chills and was given a prescription. Response 19 is selected. The patient is also a diabetic, and lab work showed the patient was hyperglycemic. He was instructed to continue to check his blood sugars and consult his primary care physician if his blood sugar continued to be elevated. Would Response 10 also be marked even though it was not the reason responsible for the ER visit?
    A: M2310, Reason for Emergent Care, reports all the reasons the patient both sought and received care in the hospital’s emergency department. Chapter 3, Response-Specific Instructions state, “If more than one reason contributed to the hospital emergency department visit, mark all appropriate responses.” Other Response-Specific Instructions use the phrases “…patient sought care…”/”…if a patient seeks care…” 

    In your scenario above, both Response 19 and 10 would be appropriate for M2310 because the patient sought care for GI flu symptoms (19-Other than above reasons) and received care for hyperglycemia (10-Hypo/Hyperglycemia, diabetes out of control).

2 Responses to “CMS Responds to Therapy Assessment Questions”

  1. Pat Fay Says:

    I am being told by the Director of PT that our therapists reassess patients on every visit so there is no need to do a comprehensive or formal reassessment and determination of progress toward goals every 30 days, as well as on the 13th and 19th aggregate therapy visit in each episode. How does CMS define Assessment and reassessment?

  2. Karen Arn Says:

    It has to be done by a qualified therapist – meaning a PT. So if there is no PTA seeing patients then that would be correct.

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