Last week, we asked for help interpreting this message from PGBA:
"Assessments must be completed and include the initial assessment, which must contain an assessment of function that objectively measures activities of daily living such as reassessments performed timely to reassess the beneficiary and compare resultant measurement to prior measurements and any assessments performed by therapist, not assistants. Also, for observations and assessments, include documentation of the beneficiary’s status after 21 days."
Director of Rehabilitation Jean-Michel Geoffriau of Sta-Home Health & Hospice in Mississippi came to our rescue.
Dear Editor:
You are correct that this Home Health Tip on Assessments from Palmetto GBA lacks clarity and as your article stated, it is based on two separate regulations. As best as I can ascertain, most of it pertains to the required Therapy reassessments which are to be completed by a qualified therapist and not by an assistant, no less than every 30 days. Such Therapy reassessments are meant to capture objective functional data, and they need to include a comparison with the prior reassessment as well as a clinical justification for the decision to either continue the therapy POC as planned, or revise it or discontinue it (CFR 40.2.1.ii). The last sentence mentions Observation & Assessment, so it seems to pertain to Skilled Nursing rather than Therapy, given the mention of 21 days (a “3-week period” in CFR 40.1.2.1).
And it is my understanding that non-compliance with both sets of regulations can trigger coverage denials.
Hope this is of help…
Jean-Michel,
It is quite helpful, thank you. It appears the people in South Carolina who have the power to pay or deny claims could use a refresher course on the CFR.
Tim