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Therapy Reassessment

Effective April 2011, qualified therapists must document therapy reassessments for their Medicare home health patients at key intervals during the patient’s course of treatment. This means these assessments must be completed by a physical therapist, an occupational therapist, or a speech-language pathologist during a regularly scheduled visit. Therapy assistants are not permitted to complete the reassessments. Since speech-language assistants are not allowed to provide services, all home health speech-language pathology visits will be provided by the speech-language pathologist. These assessments will help ensure the effectiveness of the patient’s treatment. While some agencies do not utilize therapy assistants, many do.

It is expected that therapists and therapy assistants assess the patient somewhat during each visit. A thorough reassessment is required at least every 30 days for each discipline treating the patient. The CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 7, Section 40.2.1 states: The 30-day clock begins with the first therapy service (of that discipline) and the clock resets with each therapist’s visit/assessment/measurement/documentation (of that discipline).

CMS provides this guidance regarding counting the days in the Therapy Questions and Answers-Revised February 28, 2013, Answer 7: For example, if a therapist conducted and documented an assessment of a patient during a visit on April 1, the count would begin on April 2. In this case, to meet the requirement of making at least one visit every 30 days, the therapist rather than an assistant would need to return by May 1. The therapist then conducted and documented an assessment of the patient during a visit on May 1, the clock resets and the next 30-day count would begin May 2.

Additionally, a reassessment must be completed at visit 13 and again at visit 19. Additional flexibility exists for patients receiving multiple disciplines of therapy as well as for patients living in rural areas or when there are exceptional circumstances. There has been much discussion about this requirement. This article shows a few examples of when the reassessment is needed. These are only examples.

Example 1 - One Therapy Discipline

A patient is receiving only PT 3 times a week for 3 weeks and then 2 times a week for 5 weeks. Some visits are provided by a PTA. The schedule may look like this:

May

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
1   2 PT 3   4   5 PTA 6 PT 7  
8   9 PTA 10   11   12 PT 13 PTA 14  
15   16 PTA 17   18   19 PT 20 PTA 21  
22   23 PT 24   25   26 PTA 27   28  
29   30 PTA 31                  

June

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
            1   2 PT 3   4  
5   6 PTA 7   8   9 PTA 10   11  
12   13 PT 14   15   16 PTA 17   18  
19   20 PTA 21   22   23 PT 24   25  
26   27   28   29   30          

By day 30, June 1, 12 PT visits have been provided. A therapy reassessment must be completed by a physical therapist by that day. Since no visit is scheduled for that day, it must have been completed prior to June 1. The agency could choose to have the physical therapist provide services and a reassessment earlier than visit 12 but it must occur at least every 30 days. This provider decided to have the therapy reassessment performed on May 23. Visit 13 will occur on the second of June. A therapy reassessment must be completed on visit 13.

Another reassessment must be completed on visit 19 which occurs on the 23rd of June.

Example 2 - Two Therapy Disciplines

A second patient is receiving PT 3 times a week. OT twice a week was added 3 weeks into the episode. Some visits were provided by PTA and OTA. This is a possible example of the first month:

May

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
1   2 PT 3   4 PTA 5   6 PTA 7  
8   9 PTA 10   11 PTA 12   13 PTA 14  
15   16 PT 17   18 PTA
OT
19   20 PTA
OTA
21  
22   23 PT 24   25 PTA
OT
26   27 PTA
OT
28  
29   30 PTA 31                  

Reassessment is needed by the 25th of May by both the occupational therapist and the physical therapist as visits 13 and 14 occur that day. One of the reassessments must be completed prior to this date.  In this example, the PT reassessment was done on visit 12 on the 23rd of May. The occupational therapist performed the OT reassessment on May 25 at visit 13.

Treatment is continued by both disciplines into June. This example calendar is below.

June

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
            1 PT
OT
2   3 PTA
OTA
4  
5   6 PTA 7   8 PTA
OT
9   10 PT
OTA
11  
12   13 PT 14   15 PTA
OT
16   17 PTA
OTA
18  
19   20 PTA 21   22 PTA
OTA
23   24 PT
OT
25  
26   27 PTA 28   29 PTA
OTA
30          

A reassessment for both PT and OT must be done by the 19th visit which occurs on June 1. This provider chose to have both the PT and the OT reassessment performed on that date. 

If treatment continues into the next episode, a therapy reassessment must be completed by the first of July, 30 days following the reassessment for visit 19. Additionally, a reassessment will be needed by visit 13 and 19 of that episode as well as at least every 30 days.

Example 3 - Three Therapy Disciplines

A third patient requires PT and OT twice a week. SLP is needed twice a week for two weeks and then once a week for two weeks. Visit 13 occurs on the 16th of October. The physical therapist, occupational therapist and the speech-language pathologist must all have completed their reassessment during a scheduled visit by this date. In this example, the SLP completed a reassessment on the 11th. The occupational therapist completed a reassessment on the 13th. The physical therapist completed a reassessment on the 16th. This is only an example.

October

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
1   2 PT
SLP
3 OT 4 PTA
SLP
5   6 OTA 7  
8   9 PTA
SLP
10 OTA 11 PT
SLP
12   13 OT 14  
15   16 PT 17 OTA 18 PT
SLP
19   20 OTA 21  
22   23 PT 24 OT 25 PT
SLP
26   27 OTA 28  
29   30 PTA 31 OTA                

Visit 19 occurs on the 24th of October. Again the physical therapist, occupational therapist and the speech-language pathologist must have completed another reassessment by that date. In this example, the SLP reassessment was completed on October 18, the PT reassessment was on October 23, and the OT reassessment was completed on October 24.

For any disciplines continuing treatment into November, a reassessment must be completed within 30 days of the reassessment performed by visit 19. In this example, SLP will be ending services so no reassessment will be required. The PT reassessment must be completed by November 22. The OT reassessment must be completed by November 23.

Example 4 - Hospitalization during Treatment

A patient is scheduled to have PT 2 times a week. As day 30 approaches, the patient unexpectedly becomes ill and therapy is held due to the illness. The physician is notified and an order is obtained to hold therapy. The patient is then hospitalized for several days. The 30 day reassessment would have been due to be completed by May 3 in this example. The patient was hospitalized at that time. This is only an example.

April

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
1   2   3 PT 4   5 PT 6   7  
8   9 PTA 10   11   12 PT 13   14  
15   16 PT 17   18   19 PT 20   21  
22   23 PTA 24   25   26 PT held 27   28  
29 Hospitalized 30 Hospitalized                    

Following discharge, the physician orders PT to resume as previously ordered. The patient resumes home care therapy services on May 7. The PT must complete their reassessment on their first visit following the resumption. Therapy continues and a reassessment is required at visit 13, which occurs on May 23.

May

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
        1 Hospital 2 Hospital 3 Discharged 4   5  
6   7 PT 8   9 PTA 10   11   12  
13   14 PTA 15   16 PTA 17   18   19  
20   21 PT 22   23 PT 24   25   26  
27   28 PTA 29   30 PT 31          

In another agency, the PT may have chosen to do a reassessment early at visit 6 rather than waiting for day 30 of treatment. In this situation, the requirement would already have been met prior to the patient’s illness.

Therapy Hold

Questions have been asked about when the physician may order a therapy hold other than due to illness as is explained in example 4. In some instances, a patient may need to have therapy for a period of time, perhaps prior to a surgery. Therapy will be held while the patient recovers from the surgery. Then when adequate healing has occurred, therapy may be resumed. In this instance, the agency would most likely be aware that therapy will be held. In this instance, a reassessment should be performed prior to the therapy hold so the reassessment will be timely.

Example 5 - Therapy Hold

A patient is ordered to have PT twice a week for 3 weeks. The patient will then have surgery and therapy will be held until the patient has recovered sufficiently. The 30 day reassessment would normally be required by October 3. However, the PT will be on hold at that time. Because the agency was aware that the reassessment will be required during the period of the hold, the therapist should complete the reassessment prior to the hold. In this instance, the reassessment was performed on September 19, the last PT visit prior to the therapy hold. This is only an example.

September

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
    1   2   3 PT 4   5 PT 6  
7   8   9 PTA 10   11   12 PT 13  
14   15   16 PTA 17   18   19 PT 20  
21   22   23 HOLD 24   25   26 HOLD 27  
28   29   30 HOLD                

October

Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit Date Visit
            1   2   3 HOLD 4  
5   6   7 HOLD 8   9   10 HOLD 11  
12   13   14 HOLD 15   16   17 HOLD 18  
19   20   21 PT 22   23   24 PT 25  
26   27   28 PTA 29   30   31 PT    

On October 21, the patient resumes PT. It would be reasonable for the PT to do a reassessment on that date to update the care plan if needed. In this example, 10 PT visits have occurred. If treatment continues into a second episode, a reassessment will be required by 30 days from the October 21 reassessment , that is November 20. Additionally, a reassessment will be required at visit 13 and visit 19 of the episode.

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