New CMS guidelines for Therapy Services Provided by Home Health Agencies


Therapy Requirements Fact Sheet

While changes to Publication 100-02, Chapter 7, Home Health Services are pending, the following information related to therapy requirements contained in the Calendar Year 2011 Final Home Health Rule is being provided to assist HHAs and therapists with these requirements that are effective April 1, 2011.

Assessment, Measurement and Documentation of Therapy Effectiveness

To ensure therapy services are effective, at defined points during a course of treatment, for each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must perform the ordered therapy service. During this visit, the therapist must assess the patient using a method which allows for objective measurement of function and successive comparison of measurements. The therapist must document the measurement results in the clinical record. Specifically:

Initial Therapy Assessment

  • For each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must assess the patient’s function using a method which objectively measures activities of daily living such as, but not limited to, eating, swallowing, bathing, dressing, toileting, walking, climbing stairs, using assistive devices, and mental and cognitive factors. The measurement results must be documented in the clinical record.
  • Where more than one discipline of therapy is being provided, a qualified therapist from each of the disciplines must functionally assess the patient. The therapist must document the measurement results which correspond to the therapist’s discipline and care plan goals, in the clinical record.

Reassessment at least every 30 days (performed in conjunction with an ordered therapy service)

  • At least once every 30 days, for each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must provide the ordered therapy service, functionally reassess the patient, and compare the resultant measurement to prior assessment measurements. The therapist must document in the clinical record the measurement results along with the therapist’s determination of the effectiveness of therapy, or lack thereof.
  • Where more than one discipline of therapy is being provided, at least once every 30 days, a qualified therapist from each of the disciplines must provide the ordered therapy service, functionally reassess the patient, and compare the resultant measurement to prior assessment measurements. The therapist must document in the clinical record the measurement results along with the therapist’s determination of the effectiveness of therapy, or lack thereof. In multi-discipline therapy cases, the qualified therapist would reassess functional items (and measure and document) those which correspond to the therapist’s discipline and care plan goals.

Reassessment prior to the 14th and 20th therapy visit

  • If a patient’s course of therapy treatment reaches 13 therapy visits, for each therapy discipline for which services are provided, a qualified therapist (instead of an assistant) must provide the ordered 13th therapy service, functionally reassess the patient, and compare the resultant measurement to prior measurements. The therapist must document in the clinical record the measurement results along with the therapist’s determination of the effectiveness of therapy, or lack thereof.
  • Similarly, if a patient’s course of therapy treatment reaches 19 therapy visits, a qualified therapist (instead of an assistant) must provide the ordered 19th therapy service, functionally reassess, measure and document effectiveness of therapy, or lack thereof.
  • When the patient resides in a rural area or when documented circumstances outside the control of the therapist prevent the qualified therapist’s visit at exactly the 13th visit, the qualified therapist’s visit can occur after the 10th therapy visit but no later than the 13th visit. Similarly, in rural areas or if documented exceptional circumstances exist, the qualified therapist’s visit can occur after the 16th therapy visit but no later than the 19th therapy.
  • Where more than one discipline of therapy is being provided, a qualified therapist from each of the disciplines must provide the ordered therapy service and functionally reassess, measure, and document the effectiveness of therapy or lack thereof close to but no later than the 13th and 19th therapy visit. The 13th and 19th therapy visit timepoints relate to the sum total of therapy visit from all therapy disciplines. In multi-discipline therapy cases, the qualified therapist would reassess functional items and measure those which correspond to the therapist’s discipline and care plan goals.
  • Therapy services provided after the 13th and 19th visit (sum total of therapy visit from all therapy disciplines), are not covered until:
    • The qualified therapist(s) completes the assessment/measurement/documentation requirements.
    • The qualified therapist(s) determines if the goals of the plan of care have been achieved or if the plan of care may require updating. If needed, changes to therapy goals or an updated plan of care is sent to the physician for signature or discharge.
    • If the measurement results do not reveal progress toward therapy goals and/or do not indicate that therapy is effective, but therapy continues, the qualified therapist(s) must document why the physician and therapist have determined therapy should be continued.

Axxess is offering an seminars on April 20 and 27, 2011 in Dallas and Houston respectively to educate home health agencies about the new requirements. You may sign up for the seminars at www.axxessconsult.com/seminars

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