HH PPS 2011 Therapy Final Rules: What Agencies Need to Know

8/3/2019 HH PPS 2011 Therapy Final Rules: What Agencies Need to Know

1/29

2011

Cindy Krafft, MS, PT

Director of Rehabilitation Consulting Services

Fazzi Associates, Inc.

HH PPS 2011 Therapy Final Rules:

What Agencies Need to Know

March 24, 2011


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2011

Objectives

Review the key concepts in PPS 2011 as theyrelate to therapy services

Examine the critical elements for compliance

with the documentation expectations

Explore options for coordinating care forreassessments

Clarify issues surrounding MaintenanceTherapy


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2011

Therapy in Home Health

Must relate directly and specifically to atreatment program that is designed to treatthe beneficiarys illness or injury.

General physical welfare is not consideredskilled care.

Transient and easily reversible loss orreduction of function does not support theneed for therapy.


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2011

What is Medical Necessity?

Necessity is definedas:

An imperative

requirement or needfor something

Indispensability


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2011

Focus of the New Rules

Documentation!!

Documentation!!

Documentation!!

Effective

April 1, 2011


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2011

Coverage Issue

Therapy would notbe covered to effectimprovement orrestoration offunction when apatient suffered atransient and easily

reversible loss orreduction offunction.


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2011

Requirements for Coverage

1. Course of therapy (treatment andgoals) consistent with the findings ofthe evaluation of function.

2. Follow accepted professionalstandards of clinical practice.

3. Goals must be measureable and

pertain directly to the patient.4. Includes objective measurements of

function.


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2011

Assessment Issues by Discipline

Physical Therapy Gait more than distance, device and level ofassistance

Occupational Therapy ADLs and IADLS should not be assessed as a

group of tasks Speech Therapy

Clarity of functional impact of testing

Bottom Line

quantity AND quality of patientperformance


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2011

Assessment Tips

Pain

Directly relate to functional impact

Transfers

Specific components of task

Balance

Functional Reach

Single Leg Stance..

Ambulation

Gait cycle


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2011

Assessment Tips

Self Care

Quality of life measures

Home Management

TUG Cognitive / Functional

Communication

Impact on entire plan of care

Cognition

Safety and caregiver education


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2011

Accepted Standards of Practice

ASHA

www.asha.org

AOTA

www.aota.org

APTA

www.apta.org www.homehealthsection.org

Membership mayincrease access.
http://www.asha.org/http://www.aota.org/http://www.apta.org/http://www.homehealthsection.org/http://www.homehealthsection.org/http://www.apta.org/http://www.aota.org/http://www.asha.org/


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2011

Well Written Goals

Address for what / so

what.

A connection of themovement/activity to aspecific function.

Framework for progressover the course of care.

Can / should be updated.


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2011

Tests and Measures

Standardized Must follow thedirections

Validated

Assess researchbehind the tool

Value in repeatingover course of care Support ongoing

need and impact ofcare


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2011

Why Reassessments?

We believe that when a uniquecondition of an individual patientrequires more therapy than a typical

Medicare HH rehabilitation patient,such a patient should be more closelymonitored by a qualified therapist toensure high-quality, effective servicesare being provided and/or acceptableprogress towards goals is beingachieved.


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2011

Reassessment Timeframes

Minimally every 30 days

Key areas around 13and 19 total therapyvisits.

Done by qualified

therapist who actually

participates in theassessment directly.

Done as part of atreatment visit.


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2011

If One Therapy Providing Care

Reassessment required minimally every 30days.

If completing more than 13 visits the

reassessment is required on the 13th

visit. If continuing on to more than 19 visits thereassessment is required on the 19th visit.

Exceptions: 10 13 and 16 - 19

Rural area Circumstances outside the control of the

therapist


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2011

Example

Only therapy involved is SLP Reassessment required minimally every 30

days.

If plan is for 15 visits, the reassessment isrequired at #13.

If plan is for 22 visits, the reassessment isrequired at #13 AND #19.

Windows (10- 13 and 16-19) apply forpatient driven reasons.


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2011

If More Than One Therapy

Reassessment required minimally every 30days.

If completing more than 13 visits thereassessment is required by all continuing

services close to the 13th visit. If continuing on to more than 19 visits the

reassessment is required by all continuingservices close to the 19th visit.

Exceptions: Rural area Circumstances outside the control of the

therapist


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2011

Example

Patient receiving PT and OT Reassessment required minimally every 30

days.

If plan is for 15 total visits, the

reassessments are required close to butbefore #13.

If plan is for 22 total visits, thereassessment is required close to but

before #13 AND #19. Required for services that relevant.


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2011

Reassessment Documentation

Objective assessments Effectiveness of therapy in relation to the

goals. Plans to continue or discontinue

Refer to clinical findings and treatment plan

revisions. Changes in goals or an updated plan of care

MD signature required. Clinically supported statement of

expectation that the patient can continue toprogress or resume progress after plateauor regression.


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2011

Reasonable and Necessary?

If an individuals expected restorative

potential would be insignificant inrelation to the extent and duration of

therapy services required to achievesuch potential, therapy would not beconsidered reasonable and necessary,

and thus would not be covered.


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2011

Maintenance Therapy

require the specialized skills, knowledge,and judgment of the qualified therapist todesign or establish a safe and effectivemaintenance program

the unique clinical conditions of a patient

may require the specialized skills of a

qualified therapist to perform a safe andeffective maintenance program


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2011

Therapy G Codes:Restorative

G015

1

Physical Therapist in the home health or hospicesetting, each 15 minutes.

G0152

Occupational Therapist in the home health orhospice setting, each 15 minutes.

G0153

Speech-Language Pathologist in the homehealth or hospice setting, each 15 minutes.

G0157

Physical Therapist Assistant in the home

health or hospice setting, each 15 minutes.

G0158

Occupational Therapist Assistant in the home

health or hospice setting, each 15 minutes.


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2011

Therapy G Codes:Maintenance

G0159

Physical Therapist in the home health setting, in theestablishment or delivery of a safe and effectivephysical therapy maintenance program, each 15minutes.

G0160

Occupational Therapist in the home health setting, inthe establishment or delivery of a safe and effectiveoccupational therapy maintenance program, each 15minutes.

G0161

Speech-Language Pathologist in the home healthsetting, in the establishment or delivery of a safe andeffective speech-language pathology maintenanceprogram, each 15 minutes.


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2011

Focus of Care

Restorative Therapy

Intent is to improve thepatients ability to

function. Qualified therapist

establishes the plan ofcare and completesrequiredreassessments.

Therapy assistants CAN

provide care

Maintenance Therapy

Intent is to preventfurther loss of function.

Qualified therapistestablishes the plan ofcare and completes therequiredreassessments.

Therapy assistantsCANNOT provide care


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2011

Use of Therapy Assistants

Assumption is that 79% of therapy visitsare provided by the qualified therapists.

Concerns that it may have changed.

New G Codes to separate out therapistfrom therapist assistant visits.

New G Codes related to maintenancetherapy and limited use to qualified

therapist only.


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2011

Utilization of Assistants

State Practice Act Considerations

The minimum requirements

Individual experience and competence Therapist AND Assistant

Active Supervision Communication and documentation

Awareness of OASIS, Outcomes and ProcessMeasures


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2011

What does this Mean?

Assess the current status ofdocumentation.

Address content issues proactively and

directly.

Incorporate reassessment concept as

well as monitoring compliance.

Formalize maintenance therapy.

Assess use of therapy assistants.


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800

379

0361

[email protected]

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Documents

HH PPS 2011 Therapy Final Rules: What Agencies Need to Know