New Home Health Guidelines for Physical Therapy Documentation

Among the other changes, one big change in the PPS rule is therapy documentation. Again, this comes back to some of the fraud issues that have been floating around out there over the few last years. Read this expert home health training article and know more.

You may recall there's been a lot of discussion over utilization of therapy. There has been several major newspaper articles on it. The Senate has been investigating some providers on this fact. And so CMS came in and said, “Well, we're going to make some changes to therapy services and home health benefit, how they're documented, et cetera.”

They're doing this because again there's a belief that therapy is being abused and that therapy treatment decisions are being influenced by therapy reimbursement – not by the care the patients need.

So here are the key changes as per the revised home health rules. The clinical record must document that therapy treatment is in accordance with accepted professional standards. The goals must be measurable, pertain directly to the patient's illness or injury or the patient's impairments.

The use of the term “measurable” is important there as the clinical record must document use of objective measurements and that these objective measurements can be compared to successive measurements so we can use the comparison of these objective measurements to determine effectiveness as per the healthcare rules.

Well now, they're specifically talking about objective measurements in the rule itself. And so you're going to have to show these objective measurements that you used in assessing patients and determining plans of care and measuring progress because it's a requirement.

The initial assessment and reassessment of a patient's function must be performed by a qualified therapist. And at least every 30 days that qualified therapist must provide services to reassess the patient. So you can continue to use therapy assistants but the qualified therapist has to go out and reassess.

Another key change and remember the therapy threshold was moved several years ago off of 10. So now, in following after that, because they've noticed a trend in how care plan visits are going, we've added now an additional change for patients requiring 13 or more therapy visits and a similar one for patients requiring 19 or more visits.

In the 13 or more visits therapy category, the patient must receive services from a qualified therapist on the 13th visit. And during this visit, the therapist must functionally reassess the patient.

Now, as highlighted by our expert in a health system conference, there are exceptions to this qualified therapist comes out in the 13th visit requirement. If the patient is in a rural area or there are documented circumstances outside of the therapist's control that prevent the therapist from visiting on the 13th visit, the visit may occur after the 10th but it has to occur no later than the 13th.

So in other words, the patient is in a rural area so it's more difficult to get to or there are some other circumstances that prevent the therapist from going on the 13th visit. The therapist can look at doing this, you know, follow-up visit, if you will, on the 10th, 11th, the 12th or 13th visit in order to get it done. But you want to be sure you're documenting that.

If the visits aren't happening on the 13th and, you know, the rule states “outside of the therapist's control”. So again, documenting why that visit occurred on something other than the 13th visit will be important according to the home health guidelines.

If there are multiple therapies involved, multiple disciplines, a qualified therapist from each discipline must perform a visit for their discipline that occurs close to but not later than the 13th visit. So if you have PT and speech or some other combination, each qualified therapist would need to get out related to their discipline and it would have to occur before the total number of therapy visits hits 13.

And then we go to patients acquiring 19 or more therapy visits and much like the 13th, must receive services from a qualified therapist on the 19th visit.

And again, during this 19th visit, therapist must functionally reassess the patient. Again, there are exceptions. If the patient's in a rural area or again, documented circumstances outside of the therapist's control prevent the visit from occurring on the 19th, the visit may occur after the 16th therapy visit but no later than the 19th. So the 17th, 18th, 19th.

And again, if there are multiple disciplines seeing the patient, qualified therapist from each discipline must perform the visit for their discipline that occurs close to but not later than the 19th visit. So by the 19th visit, the patient's been reassessed by qualified therapist in each discipline as per the healthcare guidelines.

Subsequent therapy visits

If these requirements are not met, the therapy visits are not covered until a qualified therapist completes reassessment and objective measurement of therapy effectiveness, determined goals have been achieved or require updating and has documented measurement results and therapy effectiveness.

So again, they're really cracking down on the idea that these therapists are seeing the patients, that we have documented measurable objective standards and that the assessments are being done objectively in measurable standards on an ongoing basis.

And again, we get to the reassessment and effectiveness. The objective measurement of therapy effectiveness goes back to what we talked about earlier with, “I can use the objective measurement from the last assessment with this one to determine objectively how we're doing on meeting the therapy goals.” And then based on that objective assessment, we get to, “Have we objectively met the goals? Or do we need to update goals, et cetera?”

So this is going to require some significant changes on how you're documenting. It's going to require educating your therapy staff. Because if it's not done right and you don't meet these standards and don't get these 13th visits and 19th visits in and you don't get the initial assessments done properly, you're not going to get paid for them.

And you're going to find yourself facing a healthcare audit and paying money back. And let's, you know, be honest, auditing therapy visits have been a very popular thing over the years because of the belief that it's being abused.

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