ME--Community Health and Nursing Services (CHANS)

Thank you for taking these comments and thank you for taking on this challenging task. I wish to comment on the therapy reassessments for home health care My first comment is in regards to the proposed change of meeting the requirements for the 13th and 19th visits. When 3 disciplines are in I read the proposed rule change to read that the requirement needs to be met on the visit 11, 12 and 13 as well as 17, 18 and 19. In practice to meet such a strict schedule would not be feasable for a number of reasons. Each clinician (PT, OT and ST) may have different frequencies depending on patient need. For example a PT may see a patient twice a week while an OT might see them one time per week and speech in once a month as an example. By having a strict interpretation of the rule we would not be able to schedule according to patient clinical need without financial disincentive. I believe agencies would respond by increasing frequency of visits and some of these may not be needed visiting only to meet regulatory compliance. Also, our home care agency (and many others) works with patients that are very ill and fragile. Many of these cancel visits due to illness or MD appointments. If a patient cancels an appointment for a PT as an example then it would effect how delivery of service is made for their next visit if this visit falls under the reassessment period. In response the OT and ST visits would also potentially need to be postponed until the PT is able to get in to make a visit. At times as well patients are hospitalized. If this occurs during a reassessment period then when the patient resumes services this strict interpretation may prevent the best possible clinician from making that first s/p visit. Instead the regulation would force the clinician out that had yet to complete the reassessment. I recommend no change in language or that 2 disciplines have 4 visits to complete or 3 disciplines have 5 visits in this assessment window. Thank you