The requirements for therapy reassessments in home care were most recently updated in the CMS 2015 PPS Final Rule for Home Health. Since January 1, 2015, the requirement from CMS is to have a qualified therapist from each involved therapy discipline perform a functional reassessment with the patient at least every 30 days.
A physical therapist, an occupational therapist, and/or a speech language pathologist is considered a qualified therapist allowed to perform a reassessment visit. Physical therapist assistants and occupational therapist assistants are not able to perform reassessment visits. When more than one therapy discipline is being provided, a qualified therapist from each discipline providing care must complete their own assessment. Completing a reassessment at least every 30 days will be unique to each therapy discipline based on the date of their initial evaluation, or subsequent qualifying reassessments.
The thirty-day clock for completing a reassessment begins with the first therapy service and resets with each qualifying reassessment of that discipline. To determine when the next reassessment would be required, counting for the “at least every 30 days” begins the day after the initial evaluation or the previous qualifying reassessment. Example: Initial evaluation is performed on June 1. The thirty-day count would begin on June 2, with the reassessment needing to be completed by July 1. A reassessment does not need to be completed exactly on day thirty. A reassessment can be performed at any time during the course of treatment. But, it must be performed no later than thirty days from the initial evaluation, or prior qualifying reassessment. Once a qualifying reassessment is performed, the thirty-day clock for the next reassessment resets.
Thirty-day reassessment requirements are measured throughout the entire course of the patient’s home care from the time of the first therapy evaluation to the time the patient is discharged from home care. The “at least every thirty-day reassessment” requirement would span from one sixty-day home care episode to the next, if recertification occurs.
Per 409.44(c)(1)(iv) reassessments need to include “objective measurements of function in accordance with accepted professional standards of clinical practice enabling comparison of successive measurements to determine the effectiveness of therapy goals.”
A reassessment needs to contain several components for it to be a qualifying reassessment. The reassessment visit needs to be recognizable and labeled as such. It must also utilize objective measurements of the effectiveness of the therapy as it relates to the set therapy goals. There needs to be a statement of the effectiveness the treatment provided, or lack thereof. The therapist must determine if the goals have been achieved, or if they require updating. The plan to continue or discontinue treatment, along with treatment plan revisions, needs to be documented in the reassessment. If ongoing therapy is planned, the documentation should support the patient being able to continue to make progress towards the therapy goals. If a reassessment does not meet the criteria of CMS guidelines, therapy visits will not be considered covered until a qualifying assessment is performed.
It is important you are familiar with, and are following, the guideline set by CMS to ensure the therapy assessments you are completing meet all requirements for a qualifying reassessment.