CMS just issued a stern reminder about therapy visits to home care providers
Home care providers slacking up on therapy under Medicare’s new payment model may want to take note of a stern reminder issued by the Centers for Medicare and Medicaid Services (CMS) last week. In a “Medicare Learning Matters” article released Feb. 10, CMS made the points that:
Patients still need therapy despite changes to therapy thresholds under Medicare’s new payment model
Home health agencies should not arbitrarily change how often therapists see homebound patients
Any reductions made in the number of therapy visits or other on-going services require advance written notice to the patient in order to comply with patient rights set out at 42 CFR 484.50, and
Therapy services help agencies obtain better outcomes and higher scores on Home Health Compare, a website designed to help patients and their families choose home health providers
“CMS reminded agencies they should not change therapy visit patterns without consulting the physician and getting approval,” said J’non Griffin, owner and president of Home Health Solutions, a consulting and outsourcing firm serving agencies nationwide.
Some home health agencies have reacted to disappearing therapy thresholds under the Patient-Driven Grouping Model (PDGM) by scheduling fewer therapy visits for their visits, J’non said, and that trend is what prompted the stern reminder from CMS in last week’s MLM article. “Basically, CMS was reminding agencies that patients still need therapy services, that the need for those services has not changed under PDGM,” she said. “And therapy services should be based on the patient need for those services.” Patient rights Agencies which do reduce or eliminate therapy services must provide patients proper written notice in advance of the reduction of services or they could be found in violation of Medicare Conditions of Participation regarding patient rights at 42 CFR 484.50, according to the MLM article. In addition to prior written notice when services are to be reduced, patients have the right to be advised of the name, address, and telephone number of the Quality Improvement Organization (QIO) in the patient’s service area if the patient has a complaint about the quality of care he/she has received, or if the patient needs to appeal a health care provider’s decision to discontinue services. Quality scores The MLM article points out that quality scores on Home Health Compare, a website specifically for helping patients and their families compare home health agencies, incorporate the use of therapy services in patient outcomes. “This is more important than ever now that CMS is requiring hospitals and post-acute facilities to help patients and their families look at patient outcomes, star ratings and quality of services offered by home health agencies in order to make the best decision about their home care,” J’non said. “These new discharge planning requirements for helping patients make a decision about home care took effect Nov. 29, and an agency’s quality therapy services are a big part of its overall patient outcomes, patient satisfaction and quality of care,” she added. In addition to general information about agencies, Home Health Compare includes information on: • Services offered (like nursing care, physical therapy, occupational therapy, speech therapy, medical/social services, and home health aide services ) • A Quality of Patient Care star rating that summarizes selected information about the performance of each home health agency compared to other agencies • Information about each home health agency’s quality of care (quality measures) and information from patients about experiences with the home health agency (patient survey results) HHS can help The number of needed visits to achieve the goals outlined on the plan of care is determined through the therapist’s assessment of the patient in collaboration with the physician responsible for the home health plan of care. Therapy does not have to be provided with an expectation of improvement in the patient’s functional impairment; it can also be provided for restorative or maintenance purposes. All therapy must be based on medical necessity for skilled therapy services – and the home health agency’s documentation must establish the patient need.
Our therapy handbook provides a short and succinct breakdown of exactly what is needed to make sure that every therapy visit is a billable one. It explains how medical necessity is adequately demonstrated in the initial assessment, shows you what the 12 components of the assessment and the 6 elements of the treatment plan are, provides specific goal-writing examples and more. It’s on sale now for $24.99 in The Solutions Shop, the online store on the Home Health Solutions website. Agencies may also want to purchase "Thinking Outside the Box for Therapy Utilization" a 60-minute webinar addressing some innovative strategies for therapy under PDGM.