CMS Website Updates Therapy Q&As

The Centers for Medicare & Medicaid Services (CMS) in March revised the questions and answers posted at the Home Health Center on its website.

Although the CMS responses do not reflect policy changes, the information offers greater clarity to therapy reassessment policy. The document can be found at Therapy Questions and Answers (Note: the date on the web link of 7/29/11 has not been update to reflect the March update).

One topic that has been confusing for home health agencies has been the question of how to count non-covered visits resulting from failure to comply with 13th and 19th visit and 30 day reassessment requirements. In this set of Q&As CMS offered the following:

“If a required therapy assessment visit were to not be performed timely (i.e. not meet the therapy assessment visit requirements), all subsequent therapy visits would be considered non-covered and would not contribute towards the counting of Medicare-covered visits used to determine when certain therapy assessment visits are to be performed. Once all therapy assessment visit requirements have been met, subsequent therapy visits would be considered Medicare-covered and would be counted for the purpose of determining when certain required therapy assessment visits need to occur.”

This guidance serves to resolve the concern about CMS’ explanation of how to determine non-covered visits presented at the National Association for Home Care & Hospice (NAHC) March on Washington which incorrectly included visits 13 and 19 in the count. However, CMS added a warning to home health agencies that only the number of visits ordered on the plan of care may be made to a patient, regardless of non-coverage of some visits.

“That said, we also note the following: (1) the classifications of Medicare-covered and non-Medicare covered visits refer to how the visits would be reported on the claim; (2) agencies and therapists should not change the number of therapy visits a patient receives based on whether prior visits were Medicare-covered or not; and (3) patients should only receive the number of therapy visits called for in the patient’s plan of care.”

The other Q&As, many of which were found in the previous Q&A posting, offer information for determining the 13 th and 19 th therapy visit and 30 th day, exceptions to the 30 day reassessment requirement, and assessment requirements in multiple therapy cases.

F2F Q&A on Therapy

Although not included in the revised therapy Q&As, CMS revealed a policy position on therapy reassessment counts in the following Q&A found in the updated Home Health Face-to-Face Encounter Question & Answers (5/4/12). According to the CMS response, home health agencies

could be out of compliance with 13 and 19 and 30 day reassessment requirements in those cases where a start of care date is altered to meet Face to Face requirements.

Q: What action must agencies take to address realignment of the 13th and 19th therapy visits when patients have late (beyond day 30) face-to-face encounters, resulting in retroactive changes to start of care dates?

A: Because the therapy visits provided before the new start of care date (post-face-to-face completion) are not covered by Medicare, those visits do not count towards the Medicare-covered visit count for assessment timing. As was discussed in the CY 2012 final rule, only Medicare-covered visits are to be considered and counted. HHAs should track both Medicare-covered and non-covered therapy visits to keep count of the appropriate number of Medicare-covered therapy visits in these situations.

Outstanding Question

At this time there remains only one question submitted by NAHC to CMS outstanding. This question has been posed to NAHC multiple times by providers seeking reassurances about their therapy reassessment responsibilities when one of multiple therapies is discharged prior to day 13 or 19. NAHC posed the following to CMS and will post the response once received:

“Agencies are seeking reassurance that they are in compliance with reassessment requirements when,  in multiple therapy cases, the reassessment visit by one or more of the therapists results in discharge by that discipline  and the single remaining therapy discipline conducts its reassessment on a “close to” visit that is earlier than the 13th or 19th. In other words, does discharge by other therapies during their planned reassessment visit change a multiple therapy case to a single therapy case, thus requiring the remaining therapy to conduct its assessment on visit 13 or 19?”

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