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The Home Health Section of the American Physical Therapy Association
Therapy Reassessments: Are You SURE You are Compliant?
A Continuing Education Audio Conference
Presented on May 9, 2013, 90 minutes
Presenters: Cindy Krafft, PT, MS, COS-C
For more information about the Home Health Section or for details about future conferences or presentations, please refer to Section’s website: www.homehealthsection.org.
PO Box 4553 • Missoula, MT 59806-4553 866.230.2980 • www.homehealthsection.org
© 2013 Home Health Section, American Physical Therapy Association. Unauthorized duplication of CDs and materials are prohibited by law. CAUTION: The Home Health Section and APTA are not responsible for the content of the enclosed presentation and make no representation concerning its accuracy or completeness. The Home Health Section assumes no responsibility for any user’s reliance upon the presentation.
The Home Health Section of the APTA was founded in 1956 as the Public Health Section. The past several years have been devoted to the development of standards of practice, education, providing information on regulatory and reimbursement issues, and developing a unified approach to the delivery of home health services.
The Home Health Section Objectives: The Home Health Section realizes the unique challenge and complexity of this setting and has developed the following objectives to meet the needs of the home health practitioner.
Keep members informed of vital issues. Share current clinical and administrative knowledge and skills pertaining to home
health.\ Encourage research and development. Monitor and actively participate in legislation related to home health care documentation
and reimbursement issues. Act as a liaison between Section members and APTA. Act as a resource to other health care organizations.
Join the Home Health Section Membership in APTA is required of all Section members and membership applications are handled through APTA’s national office in Alexandria, Virginia. You may join the Section through an online application on APTA’s website, www.apta.org, or by contacting their Membership Department at 1-800-999-2782, extension 3395. Annual dues for the Section are $35 for PT members, $30 for PTA members, $10 for Students (PT or PTA), and $10 for PT Post-Professional Students.
Home Health Section • PO Box 4553 • Missoula, MT 59806-4553 866.230.2980 • www.homehealthsection.org
Therapy Reassessments: Are You SURE You are Compliant?
Course Description
With all the focus on issues such as the impact of additional payment reductions and looming ICD 10 coming along with OASIS C-1, therapy reassessments seem to be a less important focus area. Have you read the Q and A CMS published in early March?? Far too many have not and are missing some critical clarifications that can turn your processes and billing on their heads. Audit activity in home health continues to increase and errors in timing, content or both will lead to significant revenue loss in relation to therapy visits. This session will take a straight-forward calm approach to the regulations and provide resources for agencies to confirm compliance with all aspects of the therapy reassessment requirements.
Benefits/Objectives of the Session
This session will:
Define the content expectations for documentation of therapy reassessments Discuss the timing of therapy reassessments for single and multiple therapy cases Examine the billing implications when reassessments are missed Explore justifiable situations when a reassessment is not completed timely
Presenters Cindy Krafft PT, MS, COS-C is the current President of the Home Health Section of the APTA and the Director of Rehabilitation Consulting Services for Fazzi Associates, Inc. With seventeen years of home health experience, she works with agencies and state home care associations to improve understanding and utilization of therapy services via consultation and education. She is also the Chair of the NAHC Therapy Advisory Committee. Intended Audience: This audio conference is appropriate for both clinicians and therapy supervisors/administrators. Continuing Education Credit The Home Health Section does not submit for CEU approval for audio conferences, however, your state licensure may allow credits for this education activity. You will need to contact the agency in your state handling your professional licensure in order to determine whether or not credit is available. Registrants are provided with a certificate of attendance.
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©2012
Therapy Reassessments:
Are You Sure You Are Compliant?
Cindy Krafft, PT, MS
Director of Competency Institute
Fazzi Associates, Inc.
President – Home Health Section APTA
©2012
OASIS M2200
• “In the plan of care for the Medicare payment
episode for which this assessment will define a
case-mix group, what is the indicated need for
therapy visits (total of reasonable and necessary physical, occupational, and speech-pathology
visits combined)?”
• The HHA would provide the total number of
projected therapy visits, unless NA.
©2012
Who Decides?
• “We believe that rehabilitation professionals, by virtue of their education and experience, are typically able to determine when a functional impairment could reasonably be expected to improve spontaneously as the patient gradually resumes normal activities.”
• “We expect rehabilitation professionals to be able to recognize when their skills are appropriate to promote recovery.”
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What is Medical Necessity?
• Necessity is
defined as:
– An imperative
requirement or
need for
something
– Indispensability
©2012
Documenting Necessity
• SOC / ROC OASIS
• 485 / Plan of Care
• Therapy Assessments
• Therapy Reassessments
• Therapy Orders
• Therapy Visit Notes
©2012
Therapy Assessments
• Create the foundation of the entire therapy plan of care.
• Begins to answer the question –“Why is therapy indispensible to this patient?”
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Objective Data?
• AROM/PROM?
• Manual Muscle Testing?
• Components of a Transfer?
• Gait Cycle?
• Time Based Activities?
• Pain Assessments?
• Pressure Ulcer Risk?
• OASIS?
©2012
Analysis©2012
Min / Mod / Max
• Independent, Supervision, SBA, CGA, Min A, Mod A, Max A, Total, Dependent quantifiesassistance.
• It is the qualitative measure that requires further detail about WHY the level of assist is required and WHAT skill the therapist is providing to improve the functional limitation
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Skilled Interventions
• Intervention =
“interference”
• Disruption of the
current process
• Driven by the
assessment findings
©2012
Setting Goals
What will the patient
look like as a result of the
therapy interventions?
©2012
“Measureable” Goals
• CONSIDER:
– ROM
– MMT
– Distances
– Level of assistance
– Environment
– Testing Scores
– Specific Equipment
– Caregiver role
– Specific Instructions
– Any Complicating Factors
• AVOID:
– “fair/good/poor”
– WFL
– “LRAD”
– “household”
– “community”
– “safe”
– “increase”
– “improve”
– “min/mod”
– “Modified Independent”
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“Meaningful” Goals
• Connection to what is
meaningful TO THE
PATIENT
• Consider:
– “to allow patient to”
– “so patient can”
– “to comply with” ☺☺☺☺
©2012
Reassessments
Evaluation the
plan of care for
the purpose of
determining
effectiveness.
©2012
Qualified Therapist
“We believe that when a unique condition of an
individual patient requires more therapy than a
typical Medicare HH rehabilitation patient,
such a patient should be more closely
monitored by a qualified therapist to ensure
high-quality, effective services are being
provided and/or acceptable progress towards
goals is being achieved.”
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©2012
Reassessment Documentation
• Objective assessments
• “Effectiveness” of therapy in relation to the goals
• Plans to continue or discontinue
– Refer to clinical findings and treatment plan revisions
• Changes in goals or an updated plan of care – MD signature required
• “Clinically supported statement of expectation that the patient can continue to progress” or resume progress after plateau or regression
©2012
Compliance
• Timing
– 30 days
– 13/19 visits
– Single / Multiple
– Rural / Urban
• Content
– What should a
reassessment look like?
©2012
Every 30 Days
• “Minimally”:
– Starts with the first visit
from therapy
– Continues until
discharge
– May cross certification
periods
– DON’T wait until the
last minute
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Counting Visits
13 (before 14)
Single Therapy:
– On literal 13th
– Rural exception (11-13)
– Completion resets 30 days
– Specific to each cert period
Multiple Therapy:
– Range of 11 - 13
– “Closest to” exception
– Completion resets 30 days
– Specific to each cert period
19 (before 20)
Single Therapy:
– On literal 19th
– Rural exception (17-19)
– Completion resets 30 days
– Specific to each cert period
Multiple Therapy:
– Range of 17 - 19
– “Closest to” exception
– Completion resets 30 days
– Specific to each cert period
©2012
Multiple Therapies
• PPS 2012
– Missed Reassessment impacts ALL therapy visits
• PPS 2013
– Only the therapy the missed the Reassessment is
impacted
©2012
Reassessment Quiz #1
• ST sees patient on Monday and it is the 10th visit, PT sees patient on Tuesday as the 11th visit, OT sees patient on Tuesday as well as the 12th visit and then PT sees patient on Wednesday for the 13th visit; ST has next visit on Thursday and this would be the 14th visit.
• Does ST have to change their visit day from Monday to Tuesday or Wednesday in order to be in the 11, 12, 13 mix or can they do their reassessment on Monday as the 10th visit?
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Multiple Therapies
• PPS 2012
– “Close to” 13 and 19 with no specified ranges
• PPS 2013
– Ranges of 11 to 13 and 17 to 19 in place
• Exception Process = “Closest to” the range
©2012
Exception Process
• Plot out the visits for all ordered therapies
• Determine which disciplines fall naturally
into the ranges of 11 – 13 and 17 – 19.
• If a discipline is NOT in the range, the
reassessment is due on the visit CLOSEST TO
the range
©2012
Reassessment Quiz #2
• ST sees patient on Monday and it is the 10th visit, PT sees
patient on Tuesday as the 11th visit, OT sees patient on
Tuesday as well as the 12th visit and then PT sees patient
on Wednesday for the 13th visit; ST has next visit on
Thursday and this would be the 14th visit.
• ST completes the reassessment on visit #14. Which visit
is paid and which one is not?
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When Coverage Resumes
• PPS 2012
– AFTER the Reassessment is completed
– 11, 12, 13, 14, 15(RA done), 16, 17(DC)
– Total covered visits = 15
• PPS 2013
– ON the Reassessment visit
– 11, 12, 13, 14, 15(RA done), 16, 17(DC)
– Total covered visits = 15
©2012
Reassessment Quiz #3
• ST sees patient on Monday and it is the 10th visit, PT sees
patient on Tuesday as the 11th visit, OT sees patient on
Tuesday as well as the 12th visit and then PT sees patient
on Wednesday for the 13th visit; ST has next visit on
Thursday and this would be the 14th visit.
• PT reassessed on visit #11, OT on #12 and ST on #14.
• Which service(s) are out of compliance?
©2012
Counting Visits
“Not Covered”
=
“Not Counted”
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Multiple Therapy (PT and OT)
18 total visits
• Range of 11 - 13, OT is compliant BUT PT is
not.
• … 10, 11, 12, 13, 14, 15, 16, 17, 18
• … 10, 11, 12, 12, 13, 15, 14, 15, 16
• Paid for 16 visits
©2012
Multiple Therapy (PT and OT)
23 total visits
• Ranges of 11 – 13 AND 17 - 19, OT is compliant BUT PT is not for 11 - 13.
• … 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20,
21, 22, 23 (23 MADE)
• … 10, 11, 12, 12, 13, 15, 14, 15, 16, 17, 18,
19, 20, 21 (21 PAID)
• … 10, 11, 12, 12, 13, 15, 14, 15, 16, 17, 18, 19, 20, 21 (16 PAID)
©2012
Documentation and Clinical Practice
• From the first visit to the
last, determine “why”
the patient is being
seen.
• If that question does not
have a clear answer, the
plan of care should be
reassessed.
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©2012
Helpful Resources
• American Physical Therapy Association:
– www.apta.org
• Home Health Section: www.homehealthsection.org
• State Level Associations
• American Occupational Therapy Association:
– www.aota.org
• American Speech and Hearing Association:
– www.asha.org
• National Association of Home Care
• State Home Care Associations
©2012
800 ●379 ●0361
fazzi.comfazzi.com
