IN--St Elizabeth Home Health Care

I am writing to express concern over the proposed rule for home health agencies to perform therapy reassessments within CMS defined time frames as applied to multiple discipline therapy cases. A rule that requires multiple therapy cases have all therapy services re-evaluate patients on exactly the 11th, 12th, or 13th visit and the 17th, 18th, and 19th visit, does not account for multiple disciplines seeing patients are various frequencies. If for example physical therapy is seeing a patient 3 times a week, occupational therapy 2 times a week and speech pathology only once a week, in order to have all three disciplines time their visits so that the 11th, 12th, and 13th visit all compromise different disciplines results in agencies having to spend more time and resources trying to meet regulatory requirements rather than focusing on meeting patient needs. Perhaps the speech therapist in the regular plan of care frequency made the 10th visit. Given the above example of frequencies there would be potentially 5 combined physical and occupational therapy visits clinically indicated before the next speech therapy visit. Having to make sure that visit 11, 12 and 13 are each for a different discipline would mean that agencies will have to either delay the speech visit to put it into the correct sequence, or add an additional visit just for the purpose of doing the mandated assessment. Throughout the country we are facing a shortage of qualified therapists. This is especially acute in rural areas and smaller urban areas. Agencies need to be given adequate flexibility in the timing of reassessments that this activity can be accomplished within the framework of physician ordered frequency without necessitating either delaying visits in order to meet narrow regulatory definitions or doing additional administrative non billable visits.