As every home health therapist knows, Medicare requires a 30-day reassessment at least every 30 days but where did this requirement come from and why is it so important?
In the 2011 Home Health Final Rule, the Centers for Medicare & Medicaid Services (CMS) proposed a change to the frequency of therapy reassessments and clarification as to what information was to be included in the documentation. According to the rule, MedPAC had identified a significant increase in therapy visits and had surmised that this increase corresponded with payment incentives to agency episodes with higher therapy utilization. In an attempt to control this growing issue, CMS included the requirement to functionally reassess every home health patient at least every 30 days and at the combined 13th and 19th therapy visits for all therapy that was still active at that point in the treatment plan. Compliance to the 13th and 19th visit thresholds proved complicated for most agencies as it required a level of care coordination that was difficult to achieve due to patient schedule changes and multiple disciplines involved in the care. After some adjustments to home health episode values to decrease therapy incentives and determining that the number of therapy visits had leveled out, CMS decided to remove the 13th and 19th visit counts and allow reassessments at least every 30 days in the 2015 Home Health Final Rule. This is the regulation we now follow.
So what is a 30-day reassessment? It is a visit that must be performed by a qualified therapist of each ongoing discipline at least every 30 days in the care of a home health patient. A qualified therapist is a Physical Therapist, Occupational Therapist and/or Speech Language Pathologist. Physical Therapy Assistants and Occupational Therapy Assistants are not allowed to perform the reassessment visit and Speech Language Pathologist Assistants are prohibited from providing home health services completely. The reassessment must include an “objective measurement of function in accordance with accepted professional standards of clinical practice enabling comparison of successive measurements to determine the effectiveness of therapy goals” per 42 CFR 409.44. These assessments “may include but are not limited to eating, swallowing, bathing, dressing, toileting, walking, climbing stairs, or using assistive devices, and mental and cognitive factors.” Functional tests including the Berg, TUG, Tinetti, Mini-Mental contain objective measurements to help complete your documentation. But remember to also document your interpretation of what these tests mean, how it relates to the effectiveness of the therapy treatment plan and any modifications made to the treatment plan as a result of the assessment.
This reassessment must be done at least every 30 days regardless of certification period. Any assessment can reset the 30 day “clock” and satisfy the requirement, so complete documentation on all assessments is critical to maintain compliance. The few exceptions to the 30-day timeframe include unexpected changes in the patient’s condition that lead to patient hospitalization or an unanticipated need to stop therapy due to other medical concerns. The key is that these instances should be unforeseen. If pauses in therapy can be predicted ahead of time, CMS expects that the reassessment will be performed in the visits leading up to the break in services. Documentation in the chart should reflect the abrupt nature of the gap in services and justify why the reassessment was not completed in the proper timeframe.
The consequence of missing a reassessment deadline is that all visits after the 30-day reassessment due date are considered non-billable by the home health agency. This could affect the reimbursement as adjustments in therapy visits change the episode value. Agencies unable to bill for all visits provided may withhold payment from therapy companies for those visits or even consider other, more compliant, therapy companies for future cases.
In a nutshell, CMS is looking for therapists to be mindful of treatment goals and to take a step back from the course of treatment to fully examine the effectiveness of the current therapy. Are the skills of a therapist needed to continue to treat the patient in the current or a revised treatment plan? Is the patient’s condition expected to improve or, in the case of chronic illness, is the treatment helping to slow or stop a decline in function? Is it more appropriate to discharge the patient from the therapy as skilled services may no longer be appropriate? Without a doubt CMS wants home health to function more effectively and efficiently and the 30-day reassessment is a big part of that.
therapyBOSS helps make monitoring and documentation fully compliant with little effort. therapyBOSS’ built-in 30-day reassessment note automatically pulls in documented progress toward goals and functional test scores for the last five instances of each type of test performed. There is space to summarize findings, the reason for continuing treatment, and to review and expand upon the plan going forward. therapyBOSS alerts all clinicians of the affected discipline on the care team when assessments are due and provides contracted therapy companies and home health agencies compliance tools to easily monitor the 30-day timeframe.
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