Home Health & Hospice Week

Mixing up the visit counting requirements isn't home health agencies' only mistake when it comes to the new therapy reassessment requirement. Watch out for these other common pitfalls agencies are encountering under the new mandate:

• Disorganization. "Some agencies did not start working on these new requirements at the start of the year and may not have everything in place," notes consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C. "Agencies that use a number of different contract therapists, may not have communicated all of the changes to the contracted staff and do not have in-house staff who have organized a representative group of therapists to decide on the tools to be used and establish a plan for everyone to be educated on the new rules."

If you've lagged behind on the therapy requirement due to F2F or other issues, now's the time to catch up -- before your payment or your compliance record is in jeopardy.

• Overly elaborate reassessment writeups. At the specified time points, the therapist must "functionally reassess the patient, and compare the resultant measurement to prior assessment measurements. The therapist must document in the clinical record the measurement results along with the therapist's determination of the effectiveness of therapy, or lack thereof," says the Medicare Benefit Policy Manual, newly updated on May 6.

The documentation doesn't need to be a long five-page document, emphasizes therapist and consultant Cindy Krafft with Fazzi Associates. Hitting the measurements and determination quickly and succinctly in documentation is all that's required. "Why are you making it worse?" Krafft asks agencies and therapists who are overdoing it. When new requirements take effect, "usually people are under-complying," but in this case agencies seem to be "over-complying," she observes.

• Failing to check up. HHAs may be putting a lot of effort into training and communicating with therapists on the new requirements, but then failing to check the chart as a follow-up, Adams suggests. You should ask yourself "who is checking the documentation to ensure that it meets all of the requirements?" she recommends.

• Basing care planning around the reassessment time points. "The reassessments shouldn't change care delivery," Krafft maintains. Some therapists have switched to planning care in 30-day increments, then adding more care at that point based on their findings.

"Don't write goals and frequencies to these parameters," Krafft exhorts. If you keep adding therapy at each 30-day time point, it could start to look like you're upping therapy utilization for reimbursement purposes, for one thing, she says.

Instead, therapists should just be answering the question "are we on track or do we need to change" at the 30-day deadline, Krafft says. "There's no new boundary line."

• Failing to test competencies. Especially if agencies were late in adopting measurement tools, they may not "have been able to identify and competency test therapists on appropriate evidencebasedtools related to the therapy services," Adams cautions. Now's the time to start rectifying that.