In the Home Health Proposed Rule for CY 2022 there is a proposal to update CoP 484.55(a)(2) and (b)(3) to account for a new statutory requirement that was signed into law in December of 2020 with the Medicare Home Health Flexibility Act (H.R..3127/S.1725). The requirement enables occupational therapists (OTs) to perform initial assessment visits and SOC comprehensive assessments for Medicare therapy patients under the home health benefit. Previously, only skilled nurses, physical therapists and speech language pathologists have been allowed to complete these assessments for Medicare patients, while OTs were allowed to perform subsequent comprehensive assessments.
While the act expands OTs practice at the start of a home health episode of care it does not change Medicare’s criteria for establishing eligibility for the home health benefit and OTs may only perform the initial assessment and SOC comprehensive assessment visits if:
- Skilled Nursing is not on the referral AND
- Physical Therapy and/or Speech Language Therapy is ordered for the patient.
While OTs have been permitted to conduct SOC assessments for Medicare patients since April 2020 under a temporary COVID-19 related waiver, the Medicare Home Health Flexibility Act is not affected by the PHE waivers or expirations of the waivers and will go into effect on what is expected to be a permanent basis no later than January 1, 2022.
This is significant opportunity for agencies to more fully incorporate Occupational Therapists into the patient admission and assessment processes, in preparation for the implementation of OASIS-E.
OASIS Answers, Inc. is partnering with OTs and home health agencies to support this expanding opportunity for OT’s involvement in conducting initial assessment visits and SOC comprehensive assessments for Medicare therapy patients.
Check out OAI’s HACKS Class + OT Buddy Pass offer as we welcome and encourage this expanded support for our OT colleagues.