Entry By: Eileen Bach, PT, M.Ed, DPT
Are you ready for the 2011? In transmittal 824, on 12/17/10, CMS posted the details of updated G Codes, used for billing, that will be used in 2011. The significant issues will be separating therapist from assistant visits, identifying all maintenance therapy visits and identifying RN visits for assessment and education. Pasted below is a portion of the CMS transmittal – the full details are available on the CMS website.
In order for CMS to collect more specific information regarding the sort of services provided to home health patients, we are revising the current descriptions for existing G-codes for physical therapists (G0151), occupational therapists (G0152), and speech-language pathologists (G0153), to include in the descriptions that they are intended for the reporting of services provided by a qualified physical or occupational therapist or speech language pathologist.
In addition, we are adding two new G-codes (G0157 and G0158) for the reporting of physical therapy and occupational therapy services provided by qualified therapy assistants.
• G0151 Services performed by a qualified physical therapist in the home health or hospice setting, each 15 minutes.
• G0152 Services performed by a qualified occupational therapist in the home health or hospice setting, each 15 minutes.
• G0153 Services performed by a qualified speech-language pathologist in the home health or hospice setting, each 15 minutes.
• G0157 Services performed by a qualified physical therapist assistant in the home health or hospice setting, each 15 minutes.
• G0158 Services performed by a qualified occupational therapist assistant in the home health or hospice setting, each 15 minutes.
We are also adding and requiring three new G-codes for the reporting of the establishment or delivery of therapy maintenance programs by qualified therapists. The following are descriptions for those new G-codes, for the reporting of the establishment or delivery of therapy maintenance programs by therapists:
• G0159 Services performed by a qualified physical therapist, in the home health setting, in the establishment or delivery of a safe and effective physical therapy maintenance program, each 15 minutes.
• G0160 Services performed by a qualified occupational therapist, in the home health setting, in the establishment or delivery of a safe and effective occupational therapy maintenance program, each 15 minutes.
• G0161 Services performed by a qualified speech-language pathologist, in the home health setting, in the establishment or delivery of a safe and effective speech-language pathology maintenance program, each 15 minutes.
Lastly, we are revising the current definition for the existing G-code for skilled nursing services (G0154), and requiring home health agencies (HHAs) to use G0154 only for the reporting of direct skilled nursing care to the patient by a licensed nurse (licensed practical nurse or registered nurse). Additionally, we are adding and requiring three new G-codes: One for the reporting of the skilled services of a licensed nurse in the management and evaluation of the care plan; another for the observation and assessment of a patient’s conditions when only the specialized skills of a licensed nurse can determine the patient’s status until the treatment regimen is essentially stabilized; and another for the reporting of the training or education of a patient, a patient’s family, or caregiver:
• G0154 Direct skilled services of a licensed nurse (LPN or RN) in the home health or hospice setting, each 15 minutes.
• G0162 Skilled services by a licensed nurse (RN only) for management and evaluation of the plan of care, each 15 minutes (the patient’s underlying condition or complication requires an RN to ensure that essential non-skilled care achieves its purpose in the home health or hospice setting).
•G0163 Skilled services of a licensed nurse (LPN or RN) for the observation and assessment of the patient’s condition, each 15 minutes (the change in the patient’s condition requires skilled nursing personnel to identify and evaluate the patient’s need for possible modification of treatment in the home health or hospice setting).
• G0164 Skilled services of a licensed nurse (LPN or RN), in the training and/or education of a patient or family member, in the home health or hospice setting, each 15 minutes.
We recognize that, in the course of a visit, a nurse or qualified therapist could likely provide more than one of the nursing or therapy services reflected in the new and revised codes above. HHAs must not report more than one G-code for the nursing visit regardless of the variety of nursing services provided during the visit. Similarly, the HHA must not report more than one G-code for the therapy visit, regardless of the variety of therapy services provided during the visit. In cases where more than one nursing or therapy service is provided in a visit, the HHA must report the G-code which reflects the service for which the clinician spent most of his/her time. For instance if direct skilled nursing services are provided, and the nurse also provides training/education of a patient or family member during that same visit, we would expect the HHA to report the G-code which reflects the service for which most of the time was spent during that visit. Similarly, if a qualified therapist is performing a therapy service and also establishes a maintenance program during the same visit, the HHA should report the G-code which reflects the service for which most of the time was spent during that visit.
I consider the 2011 Home Health Care changes as both a challenge and an opportunity! If you are looking to increase your knowledge and advance your skills in home health care – OR – you are thinking about starting to do home health care work, join me at one of my seminars entitled “Home Health Care: Advancing Your Skill Set“.
Wishes to all for a happy and safe holiday season. Be well!
Eileen Bach
Question: We treat home health patients in CMS rural locations. PT is the ONLY discipline in this area. Do we still get the 11-13th and 17-19th visit time frame for 13th and 19th visits? We use PTA’s to assist in care and having this “leeway” really helps in continuation of care. I wanted to clarify as you seem very knowledgable from reading this blog. Thank you.
A Green, if your agency meets the criteria for a Medicare rural home health agency, then the re-assessment time frames are 10-13 and 16-19 visits or 1 extra visit to complete the re-assessment. There is no difference in the 30 day assessment time frame for rural agencies. Your comment mentions PT as only discipline with PTA, and I am sure you are aware that the qualified therapist must complete the re-assessments.
Thanks for your positive comments re: the blog as my goal is to bring the source information to therapists in the field. Hope you find this helpful.
Best wishes,
Eileen
We are trying to fully understand how to determine the 13th and 19th visit. If the patient is being seen by more than one dicpline is the 13th visit a cumulative total for all dicplines? Is there any specific objective data that need to be included in the assessment. Thanks for your help!
Krystal, great questions about the new therapy rules.
If more than one therapy discipline is seeing the patient, then EACH therapist must complete a re-assessment between the 11th & 13th and/or 17th & 19th visit and/or 30th day. There is an exception for CMS designated RURAL agencies where they have an extra day prior – a rural agency completes the reassessment between the 10th & 13th visit for example. It is highly likely on cases with multiple therapies that the 13th/19th visit will occur before the 30th day – if that happens the 30 day clock “resets” to zero. Only combined therapy visits are counted for the re-assessment time frames.
Your second question is whether any specific objective data needs to be included in the assessment. The 2011 PPS rules identify that a therapy assessment should be objective, measurable and based on professional standards of practice. My take away is that on my initial evaluation, I should complete some standard and measurable assessments (based on my profession) so that on the 13th/19th visits or 30th day RE-assessment, I can re-assess those standard, measurable within my practice items (again) and show the progress of the therapy program. Some home care agencies are creating re-assessment forms so check with your agency. Medicare does not (and never has in the past) had a specific assessment form for the Rehab therapies to complete. In general, the focus should be on function.
One part of my Summit seminar, Home Care: Advancing Your Skill Set, covers specific and standard measures for OT, PT and SLP as well as some that may be shared across disciplines. There are many measures available and keep in mind some “tried and true” elements of therapy – such as range of motion measurements – are standard and specific. Looking at your professional tool kit to include key measures may be a helpful discussion to have at the next therapy team meeting at your home care agency.
Hope my answers have been helpful.
Best wishes,
Eileen
Thanks so much for your help. That answers our questions. My co-worker and I attented your course on fall prevention last year and it completely changed the way we treat our patients. We have had great results since implementing the changes. We look forward to attending another one of your seminars the next time you are in our area. Thanks again!
Krystal, thank you so much for the positive feedback on my Evidenced Based Falls seminar! I am so glad that the information enhanced your practice.
I created the “Home Health Care: Advancing Your Skill Set” seminar this year because I wanted to get out source information and empower therapists who work in home care. So I hope my Home Care seminar schedule does come to your area soon.
Thanks again and be well,
Eileen
Hi Julie,
Can you tell me how to count the 13th and 19 th visit within a 60 day episode if the patient had a PT evaluation and one routine PT visit on the first week of the episode and then was discontinued by MD due to medical reasons but after 5 weeks but still within the episode had another Physician order to new PT evaluation. Will that 1st 2 visits be collectively count with the new PT evaluation and subsequent visits be included in counting for the 13th visit?
Thank you.
To Joan, the new regulations count visits in each episode. So your question regarding counting visits into a re-certified case has an easy answer – the start of the recertification “restarts” the visit count. It does not matter how many visits were made in the prior certification.
Hope that is helpful,
Eileen Bach PT, M.ED, DPT
To Guia, this is the instructor responding – Eileen not Julia. Julia if you are checking in on the blog, feel free to respond as well.
Guia, the answer to your question is Yes – all therapy visits in an episode is counted towards the re-assessment points (13th & 19th visit, 30th day). In your scenario, 2 visits occurred week 1, then a gap of 4 weeks takes place and therapy is restarted. There was no active therapy taking place on the 30th day and there is only 4 or less weeks remaining in the episode period so based on the frequency (and IF more than 1 therapy is active) the need for 13th visit re-assessment may not happen. 2 visits week 1, then BIW x 4 weeks is only 10 total visits where TIW would necessitate a 13th visit reassessment before the episode ends.
The Home Care industry is also waiting to see CMS post Q&A on the new therapy rules and hopefully we will see that info soon as the start of the new therapy regulations on 4/1/11 is just 48 hours away!
Best wishes,
Eileen Bach
Hi, Julie if a 13th or 19th visit re-assessment is completed, the 30 day clock “re-sets” to zero. I believe that for most cases, that means that if 13th or 19th visit re-assessments are done, it is highly unlikely that you would need to do a 30 day re-assessment.
The opposite could happen – namely when the 30 day re-assessment is due with 1 Rehab discipline visiting 2 times a week, if the therapy plan continued at 2v, a week, a 13 visit re-assessment would need to be completed around 2 weeks later.
Hope that helps.
Eileen
Can you tell me how to count the 13th and 19 th visit if patients have already been seen by PT and then they are re-hospitalized? We would perform another new evaluation by the PT. Would the 13th visit/30 days begin from the new evaluation from the resumption of care (as we fully evaluate and make new goals) or would you still count from the start of care? Thank you.
Joan, great question! As best I know, if a patient has an interruption of care, as soon as therapy is resumed the total visit count is also resumed. So the 13th, 19th visit or 30th day re-assessments should be done if that time point occurs. Of course, if the patient is hospitalized during the 30th day, the therapy re-assessment would take place as soon as it can. Since the therapist has no requirement to do a re-assessment upon resumption of care – the only requirement is an OASIS – I would recommend a therapy re-assessment upon resumption unless there is a clear reason not to do so. So for those patients who have an interruption of care, there may be “extra” re-assessments beyond 13/19 visits or 30 day.
I hope this issue – resumption of care and the 4/1 therapy regulations – is an area that CMS posts a Q & A soon. If any further CMS info is provided, I will continue posting links here in my blog.
Best wishes,
Eileen
Thank you Eileen. I am slowly getting my brain wrapped around these new requirememts…tracking the visits will be the challenge I believe (if a patient had a missed visit, cancels, etc…).
Of topic question: what is the average time for each PT home visit? I understand evaluations, discharges take longer; what is the average time for a regular visit? Is there a minimum time required? thanks, Julie
Julie, I agree that keeping track of visits has just become super important. As to what is the average time for a therapy visit, there is no written expectation from CMS; most agencies cover this in terms of expectations or guidelines of care. You are correct that evaluations, completing OASIS, etc can take longer. Some agencies factor the varying time for care in the staff salary or per diem visit rate or in the visit productivity expectations.
Hope that is helpful! Be well,
Eileen
Thanks for the information on what to do with a resumption of care. One other question: When you have a patient that is recertified by a RN( a recret oasis done for another 60 day period), and therapy is also continuing what are the rules? If you did not yet hit the 13 or 19th therapy visit, does the visit count continue from the soc or do you start a new count for the new certification period of 60 days? (and do you recommend we do another evaluation when a recert oasis is done?)EX you hit the 13th therapy visit on day 59 of initial soc and then you see pt 2/wk for 4 more weeks. would you hit 19th visit in 3rd week, or start a new count? In this case you may have to eval pt 2 visits in a row if we do an evaluation when pt is recertified, which is what we did prior to these new re-evaltuatin rules. Thanks, Joan Begliomini
Dear Ms. Bach,
I’m a PT in PA and I’m interested to do home heath care work but is very much intimidated by not having any experience at all in this field. Your upcoming seminar “Home Health Care: Advancing Your Skill Set” is just what I needed; however, I couldn’t make the NY dates. Is there a chance you will do another one in Philadelphia or New Jersey area?
Thanks,
Janice
Thanks, Janice for your interest. Home care can be intimidating when looking in from the outside and I encourage you to keep gathering more information so you can jump in more prepared. My NY dates are in 10 days then I will be in Calif Feb and April and MI in March, Ohio and Pittsburg in May. I do not have any Philadelphia or NJ dates planned yet for 2011. Please keep checking the Summit website for updates.
In case you can make the NY dates at the last minute, please know that you can register onsite on the day of the seminar.
Best wishes,
Eileen
Would very much appreciate knowing if you will be in the Kalamazoo, MI. area or learning your upcoming schedule and locations.
Or if you offer a CD training, as well.
Henrietta, thank you for your interest!
I will be in Michigan in March 2011. The Home Health Care: Advancing Your Skill Set seminar schedule for MI in March is 3/24 Grand Rapids, 3/25 Lansing and 3/26 Troy.
I do not have plans for a CD production at this time.
Best,
Eileen
Dear Ms.Bach we would love to have you come to Oklahoma City or Tulsa OK too. Our state is a very rural area, and we service a great many patients in their homes. My expectation has always been tailored to each individual patient, and not dictated by my supervisor (who my be a nurse). Also our state has implemented more supervisory visits by the PT’s. For every quarter we must have a co-treat visit with each PTA which is documented, and conference calls or meetings to discuss the patients progress on a monthly basis. Now with the new Medicare guide lines PT’s must also reassess each patient by the 10-13 visit to determine if they qualify for more PT. I understand these rulings because I have seen HH agencies that insist that we eval and then the patient is seen by a PTA I have never met.
Sincerely, Susan Cuzzort, PT on Lawton, Ok
Wow! Susan, you point out a really important issue and your example re: PTA is scary. Having a professional license brings a responsibility and I can not imagine how a PTA the PT has never met can adequately provide the plan of care that the PT creates.
The new PPS 2011 regulations are looking to have therapy visits substantiated in many ways – new billling codes, proven MD involvement in HC plan, documentation standards and therapy re-assessment time points just to mention a few. For PT and PTA, the new rules state that therapist must visit every 30 days or 6 visits whichever comes 1st and if the case is Medicare billing, that would “trump” any state standards for assistant supervision that are lower.
I applaude your efforts in keeping up with regulations as well as striving to provide the individual with a plan of care. Cookie cutters are for baking!
My seminar “Home Health Care: Advancing Your Skill Set” was designed to bring info, strategies and materials to a practicing HC therapist such as yourself. Please check back with the Summmit website as my seminar schedule for 2011 gets finalized over the next several months.
Best wishes, Eileen
Eileen, Any chance you will do a seminar in AZ on Home health care – Are you ready for the new year?
I attended your fall prevention class in November. I know several people who would want to attend a course regarding how to be prepared for changes this year.
Thanks,
julie
Hi, Julie – I would love to be back in Arizona! I have set seminar dates with Summit through April (NY, Southern calif., MI, Northern Calif) and I am happy to see if Az can be scheduled in May or June.
Please check back on the Summit website over the next several weeks as the 1st half of the year should be completely in place soon.
Am I right in remembering you as a newer home care therapist who attended my Evidence Based Falls program in Phoenix? Hope all is well!
Best,
Eileen
Yes Eileen I have been in home health care for the last 3 years. My 23 yrs as a PT has primarily been in the private sector doing outpatient PT. I know there are many changes occuring 2011 (face to face with dr) and I want to be sure to comply with Medicare’s requirements (ie. 13th visit,etc). I find the functional tests you covered in your seminar to be very helpful in documenting progress. I will check for an AZ date. Do you have any websites you recommend to get a clearer understanding on 13th and 19th visits and what needs to be included in our documentation? Thanks, Julie
Hi, Julie, Summit and I am working on finalizing dates for July and we are working on Phoenix and Tucson, AZ locations in July. You should be able to see those dates when all details are finished on the Summit site in a few weeks.
NAHC and VNAA have information about the 2011 therapy regulations, as well as APTA. I am pasting a web link with helpful summary information as well –
http://www.fazzi.com/research-reports.html
I will enter a new blog about the delta project so it is easier to see on my blog.
I am really glad that the functional tests I discussed in the Evidenced based Falls seminar in 2010 are helpful in your practice. They are exactly what you need to be successful in producing a solid 13/19 visit or 30 day re-assessment!
See this summer in AZ,
Eileen
Thanks Eileen. I have a specific question I hope you can answer for me: Do I need to conduct the 13th and 19th reassessment in addition to the 30 day reassessment? I am confused when the 30 day needs to happen? Does this mean I may do a 13th visit functional reassessment and a 30 day reassessment in the same week? Is the 30 day reassessment a re-evaluation? Thanks for clearing this up for me.
This is the link to the CMS transmittal 824 for anyone who wants a copy of the actual notice.
http://www.cms.gov/transmittals/downloads/R824OTN.pdf
The effective date is 1/1/2011 with an implementation date of 1/3/2011.
Happy, healthy and safe New Year!
Eileen Bach
A blog responding to a blog! You are right, there are many places to work once a PT (or any other therapist like OT, ST) have completed their education and passed their examinations to be fully licensed.
Home health care as a work setting offers the therapist true one-on-one care and a focus on Function.
Best Wishes for the New Year!
Eileen