CMS Provides Guidance on 30-Day Reassessment Requirements

The Patient-Driven Groupings Model (PDGM) forced the system to value the quality of therapy visits over volume. With that being said, the 30-day functional reassessment will be more valuable than ever. Under both the Prospective Payment System (PPS) and PDGM, a functional reassessment is required to be performed at least every 30 calendar days by a qualified therapist. A qualified therapist can either be a Physical Therapist, Speech Therapist or Occupational Therapist (an assistant for any type of Therapy cannot complete this assessment).  The reassessment must include an “objective measurement of function in accordance with accepted professional standards of clinical practice enabling comparison of successive measurements to determine the effectiveness of therapy goals” per 42 CFR 409.44. These assessments may include, but are not limited to eating, swallowing, bathing, dressing, toileting, walking, climbing stairs, or using assistive device, and mental and cognitive factors.

This reassessment is required to be done, at minimum, every 30 days regardless of the certification period. If completed on day 25, the 30 day “clock” will start over. Any therapy visits done after the 30-day clock expires will need to be non-billable; therefore, it is very important you keep a close eye on this timeframe.

CMS does note that there could be unforeseen circumstances that could cause a delay in the 30-day period. Below is a summary of their response to these certain circumstances:

1. In response to those who gave hospitalizations as an example of when there should be an exception to the 30-day reassessment requirement, CMS did allow for an exception to this unexpected change in condition as follows:

“Regarding the issue of the at least every 30-days reassessment requirements…we have allowed for one exception to the 30-day reassessment requirement (that is, when there is a hold on therapy due to the patient’s hospitalization for an unexpected change in the patient’s condition). “

2. Regarding questions about 30-day reassessment requirements where unexpected sudden changes in the patient’s condition result in a need to stop therapy, CMS stated:

“We would expect to see documentation and evidence in the medical record which would support an unexpected change in the patient’s condition which precludes delivery of therapy service. The 30-day qualified therapist visit/assessment/measurement requirement can be delayed until the patient’s physician orders therapy to resume.”

3. As far as the impact of other assessments on the 30-day clock, CMS responded:

“We would like to note that every time a qualified therapist performs the therapy service, assesses the patient, measures and documents the effectiveness of the therapy service for that therapy discipline, the 30-day clock is ‘reset’. As such, a qualified therapist visit/assessment/measurement and documentation which satisfies the threshold requirement could also satisfy the 30-day requirement.”