CMS Won’t Tolerate It: Big Therapy Reductions for Your Agency Mean Big Problems!

CMS has posted a new MLN Matters article that is critical for all home health agencies. The article provides information on the continuing role of therapy under PDGM for home health periods of care starting on and after January 1, 2020.

From the MLN Matters article:

The need for therapy services under PDGM remains unchanged. Therapy provision should be determined by the individual needs of the patient without restriction or limitation on the types of disciplines provided or the frequency or duration of visits. The number of needed visits to achieve the goals outlined on the plan of care is determined through the therapist’s assessment of the patient in collaboration with the physician responsible for the home health plan of care. The home health Conditions of Participation (CoPs) (42 CFR 484.60) require that each patient must receive an individualized written plan of care. The individualized plan of care must specify the care and services necessary to meet the patient-specific needs as identified in the comprehensive assessment, including identification of the responsible discipline(s); the measurable outcomes that the HHA anticipates will occur as a result of implementing and coordinating the plan of care, and; the patient and caregiver education and training. All services must be furnished in accordance with physician orders and accepted standards of practice. Therefore, the visit patterns of therapists should not be altered without consultation and agreement from the physician responsible for the home health plan of care. Any changes to the frequency or duration of therapy visits must be in accordance with the home health CoPs at 42 CFR 484.60.

Additionally, beneficiaries must receive proper written notice in advance of the HHA reducing or terminating on-going care in accordance with the home health CoPs regarding patient rights at 42 CFR 484.50. These rights also include that the patient must be advised of the name, address, and telephone number of the Quality Improvement Organization (QIO) in the beneficiary’s service area if the beneficiary has a complaint about the quality of care he/she has received, or if the beneficiary needs to appeal a health care provider’s decision to discontinue services.

Do not gamble with the quality of your patients’ care or your agency’s future! CMS will be going over therapy reductions with a fine-toothed comb, and examples will be made. Don’t let it happen to you!

We will explore this subject and other news related to PDGM in our next issue of Home Health TodayIf you would like to receive a copy at no charge, or you would like to discuss any PDGM or billing-related issue, contact us today!