Entry By: Eileen Bach, PT, M.Ed, DPT
Pasted below is a summary from an update from HCA of NY (www.hcanys.org). The timing of the required therapy reassessments (13th and 19th visits, 30 days) is important and based on the CMS response below, when the re-assessments are late, the visits from due date to actual are not only not covered but need to be reported as non-covered in the submitted claim. Another reason for those of us working in home health to be super-organized about visits!
Happy summertime! Eileen
The U.S. Centers for Medicare and Medicaid Services (CMS) recently responded to an inquiry from the National Association for Home Care and Hospice (NAHC) about requirements related to the reporting of non-covered billing visits on Medicare claims, specifically in the case of late therapy reassessments. The required re-assessment at the 13th and 19th visits and/or 30 days have prompted questions as to the reporting of covered and non-covered services on the claim. Such questions have specifically centered on billing for late therapy reassessments and other non-covered situations. Providers have asked if it would be acceptable to omit from a claim visits that were made prior to a late therapy reassessment visit, as it has been a longstanding practice to exclude such non-covered visits from home health claims. According to CMS, “Therapy would be covered again for the visit which occurs after the qualified therapist(s) completes all the assessment, objective measurement, and documentation requirements … Asking which visit to omit [from the claim] is asking the wrong question. No visits should be omitted. The visits that are not payable should be reported with non-covered charges and will be assigned provider liability. Reporting non-covered charges is required per the Claims Processing Manual, Chapter 10, Section 40.2.”
CMS further states that when providers do not meet reassessment requirements by visits 13 and 19, non-coverage will apply to visits starting on 14 and 20 (respectively) and non-coverage will continue up to and including the visit during which required reassessments were conducted. Coverage resumes on the visit following the final reassessment visit for each respective therapy threshold. (A similar policy applies when therapists do not reassess a patient by the 30th day, with resumption of coverage on the visit following the visit on which the required reassessment is conducted.)
CMS pointed out that its intent has been for home health agencies to include all non-covered visits and charges on claims to ensure a better representation of all home health costs. Therefore, the reporting of non-covered charges shouldn’t be limited to missed therapy reassessments. Home health agencies should include all non-covered visits and charges on their claims, such as for nursing assessments, aide supervisory visits, etc.
DO nursing visits count in the total for the reassessments? Dr. Fotini Archodakis, PT, DPT, Phoenix, Arizona
Fay, nursing visits do NOT count in the visit count for re-assessment at 13 and 19 cummulative visits. Any PT, OT or SLP visit in the episode counts.
Best wishes,
Eileen
Eileen – When a timed re-assessment is missed for therapy, the visits that are done by homecare clinicians are not billable until it is made back up correct? What about nursing visits, are those non-billable as well???
Greg, I apologize for the delay in my response.
You are correct, when a required therapy re-assessmentis missed, any therapy visits made are not billable until the re-assessment is complete. This assumes that the other therapy completed any re-assessment needed for that discipline.
My understanding is that nursing visits made during the period where the therapy re-assessment is late/not completed, are not included in this billing issue.
Best wieshes,
Eileen
If a client is receiving PT/OT disciplines, is the the functional re-assessments on the the 11th and 12th visit acceptable? Is it required to do on the 12th and 13th visit if no speech involved?? I am not sure if I am making the timed functional reassessments requirement more complicated at the 11,12,13 visits window. We are trying hard to communicate missed therapy visits and may end up too earlyor being late!
Roseann, your example of 2 Rehab services (PT, OT) completing the re-assessment visits on 11,12 visits is okay. CMS allows some flexibility stating it should be done close to the 13th visit. Only when there is one therapy only visiting then the reassessment must be made on exact 13th visit.
Communication is really important when there are multiple therapists visiting, and being late (after the 13th) has a fiscal consequence for the agency. It sounds like you are doing a good job keeping in touch with team members.
Best wishes,
Eileen
Trey, I couldnt agree with you more!
Trey and Susan, I agree that documentation standards in home care has really increased over the past decade. The extra page or 2 that Trey describes is not necessarily CMS based – most often that is your agency’s interpretation. I hope you have a licensed therapy manager and a voice in what forms your agency develops. There is no more powerful voice about what works that a therapist in the field providing feedback. Wishing you both vocal access!
Eileen
Trey…I could not agree more on every issue you mentioned. You covered the bases on such ridiculous new paperwork.
The real issue is: how to get rid of all this ridiculous re-assessing (i.e. – an extra 3 or 4 page form to fill out) IN ADDITION to a skilled visit.
It is especially ridiculous when multiple therapy providers are involved. As a PT, I do an Eval, then comes OT, then maybe SLP, and so on my 3rd or 4th treatment visit, CMS says “show me the results” when in reality we are all just getting started.
I am wise to the idea that they are trying to bury us in paperwork to decrease utilization.
Shame on CMS and those who follow. Read my treatment notes for a change. I am tired of summaries of notes, notes about notes, 2-week summaries, progress notes about progress, memos about memos, and having meetings to talk about meetings. All of this is demeaning and does nothing for the patient.
It is like writing lines in elementary school: “I will not talk in class” but doing it 10 million times.
Trey Duhon, MPT, MS
Lafayette, LA